Detailed Information on the
Lead Hazard Grants Assessment

The Administration proposes to revise the rating factors for grant applicants to target funds toward more cost-beneficial technology so that more units can be made lead-free for the same dollars.

Measure: Number of children under age 6 with elevated blood lead levels.

Explanation:Childhood lead poisoning is a major health problem for which "the major source of lead exposure among U.S. children is lead-based paint and lead-contaminated dust found in deteriorating buildings." Children under age 6 are the people most at risk from lead poisoning "because they are growing so rapidly and because they tend to put their hands or other objects into their mouths" and, thereby, ingest lead-containing dust, the primary pathway of lead exposure. (www.cdc.gov/nceh/lead/faq/about.htm) In May 2005, the Centers for Disease Control and Prevention (CDC) estimated that 310,000 children had elevated blood lead levels during 1999 2002, the most recent reporting period of its National Health and Nutrition Examination Survey. The 2006 target reflects a shift in the tracking method to use the CDC results published each year based on its ongoing survey with data collected 2-3 years beforehand. The CDC conducts its survey annually, and reports blood lead level results as it deems appropriate after scientific review.

Measure: Number of housing units made lead-safe with program grant funds.

Explanation:HUD's lead hazard control grant programs assist States, Native American Tribes, local governments, and the private sector in creating wide-ranging programs to identify and control lead-based paint hazards in eligible privately owned housing, and develop a sustainable local infrastructure for continuing this work beyond the life of the grants. (www.hud.gov/offices/lead/grantprograms.cfm) The grants are awarded on a competitive basis annually. * This 2005 reduction from 2004 reflected alternative procedures used for awarding 2004 grants, which decreased the grant program's productivity in the subsequent year. The program performance was restored by 2006.

Measure: As part of a 10-year effort to eradicate lead hazards, 9,000 units will be made lead safe in FY 2008 pursuant to enforcement of the Department's lead safety regulations.

Explanation:In 2000, HUD, EPA, CDC and other Federal agencies developed the 10-year Federal strategy for eliminating childhood lead poisoning as a major public health problem by 2010. (www.hud.gov/offices/lead/library/hhi/FedLeadStrategy2000.pdf) HUD enforces its regulations for the disclosure of known lead information during sale or lease of pre-1978 housing, and for the evaluation and control of lead hazards in HUD-assisted and -owned pre-1978 housing. (www.hud.gov/offices/lead/enforcement/regulations.cfm) The number of units made lead safe indicates the improvement in residential lead exposure conditions as a result of enforcement of the regulations. The output has a health consequence of reduced lead exposure, which ultimately contributes the outcome of reduced childhood lead poisoning.

Measure: Lead Hazard reduction cost per housing unit (New measure, added February 2008)

Explanation:This efficiency measure addresses how federal funds are used to produce the output of housing units made lead safe through the lead hazard control grant program. The measure is defined as the ratio of the federal expenditures (program costs) divided by the number of housing units made lead safe, so improvement in the measure is indicated by a decrease in program costs per housing unit made lead safe.

Is the program purpose clear?

Explanation: The purpose of the program is to eliminate childhood lead poisoning, which is life-threatening and detrimental to physical and mental development. Its focus is on eliminating lead hazards in low-income housing.

Evidence: This goal, slated to be achieved by 2010, is articulated in HUD's Strategic Plans and in a report by the interagency task force on children's health and safety.

Does the program address a specific and existing problem, interest, or need?

Explanation: The CDC documents that 434,000 children (as of 1999-2000) have elevated blood lead levels. A leading cause of elevated blood lead levels is residential exposure. Low-income children have higher than average prevalence of elevated blood lead levels. In 2000, HUD documented that 1.2 million housing units had lead hazards and housed low-income families with children under age 6.

Evidence: The National Health and Nutrition Examination Survey is one documentation of childhood lead poisoning.

Is the program designed so that it is not redundant or duplicative of any Federal, state, local or private effort?

Explanation: There is no other federal program that focuses on eliminating residential lead hazards. (Assisted housing programs that are otherwise required to eliminate lead hazards are ineligible for this program). State and local programs exist but are not of sufficient scale to make significant contributions to solving the problem; they can however complement the federal effort. Grantees are required to put up matching funds. Although private investment does reduce lead hazards through renovation or demolition, the pace of these activities in low-income housing is slow.

Evidence: A report by the interagency task force on children's health and safety describes the various roles played by federal agencies.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: This program supports elimination of lead hazards in low-income housing that otherwise are not likely to be addressed through normal rehabilitation and demolition activities. Low-income housing tends to be older and unrenovated and consequently contains a high incidence of lead hazards. A regulatory approach that mandated elimination of lead hazards would result in increased housing costs, reducing the supply of affordable housing.

Evidence:  

Is the program effectively targeted, so program resources reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: There are mixed results for this program; hence the weight of this question is reduced. In some ways, it is well targeted. The program is required to serve housing affordable for low-income households. The grant application process favors those that show the most need and maximize the impact of funds. The program's effectiveness in targeting resources toward the higest level of beneficiaries should be enhanced by developing more aggressive targets for production. Its effectiveness at targeting resources toward the highest need is also threatened by funding set-asides that distribute grant funds using direct and indirect measures of need. The existing program's method for allocating funds is more effective at allocating resources because it relies solely on direct measures of need. Set-asides also complicate administration of the program.

Evidence: Requirements included in the Notice of Funding Availability.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program has an outcome goal of eliminating childhood lead poisoning. This is the primary benefit of reducing residential lead hazards.

Evidence: This goal is articulated in HUD's Strategic and Performance Plans.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The program has set a goal of eradicating childhood lead poisoning by 2010.

Evidence: Performance Reports and Plans

Does the program have a limited number of specific annual performance measures that demonstrate progress toward achieving the program's long-term measures?

Explanation: Performance measures track the contribution of this program to making housing units lead-safe.

Evidence: Performance Reports and Plans

Does the program have baselines and ambitious targets and timeframes for its annual measures?

Explanation: While the program has good baselines, there is a wide gap between the targets set for the program and the targets that would be necessary to achieve the ambitious goal of eradicating childhood lead poisoning by 2010. The inter-agency strategy envisions that, on a per dollar basis, many more housing units will be made lead-safe than are reflected in this program's targets. For this program to make an aggressive contribution to this goal, higher targets are necessary and these and other resources must be used more efficiently.

Evidence: Performance Reports and Plans, inter-agency strategy.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, etc.) commit to and work toward the annual and/or long-term goals of the program?

Explanation: Grantees have to meet minimum standards to conitnue receiving funds under the program. Grantees are now requireed to develop a statewide or jurisdiction-wide strategic plan to eliminate childhood lead poisoning.

Evidence: Grantee agreements, Notices of Funding Availability

Are independent and quality evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Detailed, peer-reviewed studies are conducted that document reductions in lead hazards and children's blood levels as a result of rehabilitation funded by the program. Research has also been effective at identifying cost-effective ways of reducing lead hazards.

Evidence: The Lead Hazard Reduction Evaluation Report

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The budget request for this program makes clear the amounts necessary for technical assistance as well that available for grants. Full cost data are also provided.

Evidence: HUD Budget Submission

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The program has developed good performance measures and taken steps to streamline administration of the program and identify sound technologies for reducing lead hazards.

Evidence: Performance Reports and Plans, inter-agency strategy. Technical research studies.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The program uses detailed progress reports to track the completion of work by grantees.

Evidence: Program Progress Reports.

Are Federal managers and program partners (grantees, subgrantees, contractors, cost-sharing partners, etc.) held accountable for cost, schedule and performance results?

Explanation: Grantees must meet minimum performance requirements to continue receipt of funding under the program. They are also eligible for competitive performance renewals if they exceed performance incentives. Program managers are appraised as to the quality of oversight and delivering performance.

Evidence: Grantee agreements, Notices of Funding Availability

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: The program does not have an excessive amount of carryover funds. Grantees that are slow to use funds are monitored by the program office and funds are recaptured if not used in a timely fashion.

Evidence: Grantee progress reports.

Does the program have procedures (e.g., competitive sourcing/cost comparisons, IT improvements, approporaite incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program does not use efficiency measures.

Evidence:  

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program worked with other federal agencies to create a strategy for eliminating childhood lead poisoning by 2010. It has also worked with state and local governments to study the effectiveness of lead intervention strategies.

Evidence: A report by the interagency task force on children's health and safety describes the various roles played by federal agencies. Research studies on lead intervention strategies.

Does the program use strong financial management practices?

Explanation: No control issues have been identified in audited financial statements. Grantees submit detailed information on spending.

Evidence: Audited Financial Statements, Grantee progress reports.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The program has taken steps to streamline the grant application and award process and to highlight cost-effective technologies for reducing lead hazards.

Evidence: Notice of Funding Availability and research studies.

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: The program distributes funds through a Notice of Funding Availability competitive process that clearly identifies rating factors for assessing applications.

Evidence: Notice of Funding Availability.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Grantees must report on their progress and are subject to escalating levels of review should they be at risk of failure to perform.

Evidence: Grantee progress reports.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: Grantee progress reports are made available on the World Wide Web.

Evidence: Grantee progress reports.

Has the program demonstrated adequate progress in achieving its long-term outcome performance goals?

Explanation: The prevalence of elevated lead blood levels has declined dramatically among children, from 890,000 in 1991-94 to 434,000 in 1999-2000. This program has made a notable contribution by making over 44,000 units lead-safe, helping to establish an infrastructure of worker skills and training, funding research on the effectiveness of technology, and fostering broader awareness of the issue. While it has been successful, it is necessary for it to achieve a broader reach and be more cost-effective (while employing sound technologies) to make more of an impact on the long-term goal of eliminating childhood lead poisoning.

Evidence: The National Health and Nutrition Examination Survey. Program Progress Reports.

Does the program (including program partners) achieve its annual performance goals?

Explanation: As noted above, the program has met its annual targets but these need to be more aggressive and funds must be used more efficiently to warrant higher ratings.

Evidence: Performance Reports

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program performance goals each year?

Explanation: The program has exhibited some decrease in gross costs per unit treated, declining from $16,000 per unit to just under $10.000 per unit. It is difficult, however, to make a definitive conclusion on efficiency trends given that support costs have varied over the life of the program and cannot be separated from direct costs easily.

Evidence: Program cost data.

Does the performance of this program compare favorably to other programs, including government, private, etc., that have similar purpose and goals?

Explanation: Although there are no equivalent programs, HUD has supported a study comparing the effectiveness of lead hazard control treatments mandated by a Massachusetts law with treatments conducted by HUD-funded programs within that state. The findings indicated that the average blood-lead levels of children were significantly lower in the homes treated through the HUD-funded programs vs. those treated in compliance with state law. Due to the lack of closely comparable programs, however, the weighting for this question is reduced.

Evidence: Massachusetts study.

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: Detailed, peer-reviewed studies have documented that significant reductions in lead hazards have resulted from work funded by the program.

Evidence: The Lead Hazard Reduction Evaluation Report