Detailed Information on the
Indian Community Development Block Grant Program Assessment

HUD will work with tribes to develop more detailed outcome performance measures and reporting. HUD will also develop a better data base of performance information.

HUD will perform a comprehensive evaluation of the program.

HUD will develop a better data base of performance information.

Measure: Jobs Created

Explanation:This goal measures the number of jobs created as a result of ICDBG funds used to economic development projects. Targets may vary as the number of applicants proposing to undertake economic development projects may vary from year to year.

Measure: ICDBG grant balances

Explanation:This goal measures year over year reduction in grant balances to ensure ICDBG recipients are effectively and efficiently spending grant funds towards approved projects. It is important to spend grant funds in a timely manner in order to ensure projects are being completed and funds are not wasted.

Measure: Training for Grantees

Explanation:Each Field Office to conduct training for new grantees on ICDBG program including reporting requirements

Measure: Reporting by Grantees

Explanation:Achieve a 90% reporting rate for ICDBG grantees

Measure: Amount of ICDBG dollars spent per community facility built.

Explanation:

Measure: Amount of ICDBG dollars spent per housing unit rehabilitated.

Explanation:

Is the program purpose clear?

Explanation: The primary objective of the Indian Community Development Block Grant (ICDBG) Program is the development of viable Indian and Alaska native communities, including decent housing, a suitable living environment and economic opportunities principally for persons of low and moderate incomes. As part of the 2004 ICDBG Notice of Funding Availability (NOFA) process, grantees will begin to specifically define how they plan to make their community more viable through outcome measures.

Evidence: In comparison to the regular CDBG program, the ICDBG program has a more clear purpose and mission. First, grantees must establish a geographic target area within the jurisdiction (or the entire area if the population of members is under 10,000), which reinforces the primary purpose of the program to improve areas or communities. Second, eligible activities include improving housing, community facilities and economic development focus on improvement of an area and largely avoid funding projects that assist individuals or families. Lastly, ONAP is able to further define the program through the grant selection criteria, which focus on capacity, need/extent of the problem, soundess of approach, leveraging and comprehensiveness/coordination. The Housing and Community Development Act of 1974, as amended, and the ICDBG regulation at 24 CFR 1003.2 outline the purpose of the program.

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

Explanation: The ICDBG Program addresses the needs of low and moderate income persons by providing a suitable living environment, decent housing and economic opportunities. The ICDBG Program provides funding through a competitive process which awards points for the low-mod income benefit; job creation; and need of the applicant to address existing problems. Census 2000 revealed that Native American and Alaska Native communities are one of the largest growing populations in our country. Such rapid growth is putting extreme stress on existing water and sewer systems in these communities.

Evidence: According to recent Census figures, unemployment on Indian reservations is over twice the national average at 13.6% (national average is 5.8%). The median income of households is the second lowest in the country ($32,116). The poverty rate for Native Americans is 26 percent, which is more than twice the average for all Americans. According to the Census, 14.7 percent of homes are overcrowded compared to 5.7 percent of homes of the general U.S. population and 11.7% of residents lack complete plumbing compared to 1.2% of the general U.S. population. Some evidence suggests that Census data may even understate the overcrowding and other problems.

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

Explanation: Duplication exists with other Federal and local programs that address various aspects of community and economic development.

Evidence: The Indian Housing Block Grant (IHBG) Program and other programs administered by the BIA, IHS, USDA, EDA and CDFI fund various aspects of community and economic development in Indian locations. Tribes are not eligible for most State and some Federal programs (e.g., HOME, McKinney Act, and Youthbuild) which provide similar types of assistance. While tribal governments do fund similar projects, most tribal governments lack adequate revenues and resources.

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

Explanation: A competitive process gives HUD the ability to target resources to areas of greatest need (see 1.5) and to determine where capacity exists to ensure success. Single purpose grants provide funds for projects consisting of an activity or set of activities designed to meet a specific community development need.

Evidence: Funds are provided through a formula to the Office of Native American Programs (ONAP) field offices, which award funds through a competitive process. The NOFA establishes funding criteria including sections on the proposed plan, tribal capacity, need, leveraging, and results. Eligibility criteria are clearly outlined in the regulations and performance reports addressing the progress made in completing activities are submitted annually.

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

Explanation: The program is targeted by a formula allocation to ONAP field offices, then by a competitive process to grantees. Program data from funded applications sugggest the program targets the most distressed areas.

Evidence: Funds are targeted by formula to each ONAP area and then by funding projects. The formula weights according are as follows: share of eligible Indian population (40%); the extent of poverty (40%); and extent of overcrowded housing (20%). ONAP offices then awards funds based on criteria, including need and extent of the problem. Approximately 75% of all grantees awarded funds in FY03 had percentages of low-or mod-income persons that were above the national average (57%) in Indian country.

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 ICDBG long-term goals proposed relate to HUD's Strategic Plan (SP). ONAP is in its 2nd year of developing and implementing a performance measurement system that will begin to track the programs output and outcome accomplishments. ICDBG will require tribes to track several new outcome measures beginning in 2004, some of which will be aggregated for the program.

Evidence: New outcome measures to be reported by 2004 grantees include, where applicable: a) reduction in the number of families living in substandard housing; b) increased standard of living resulting from employment generated by project;c) percent of residents with access to public service quality of life due to services provided by the public facility; d) increased economic self-sufficiency of recipients of program beneficiaries;e) increased homeownership rates; and f) reduction of drug-related crime or health related hazards.

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

Explanation: While ICDBG has long term targets and baselines for several performance mreasures, the baselines and targets for the new outcome measures have not yet been established.

Evidence: See measures tab.

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

Explanation: The ICDBG annual measures relate to HUD's Strategic Plan (SP) and address ICDBG in the following areas: Strengthening Communities, Embracing High Standards of Ethics, Management and Accountability; ICDBG will track several new annual measures the FY04 ICDBG NOFA, in addition to the existing measures. New measures and some of the existing measures such as number of jobs created and number of public facilities built have a direct link to the program's purpose.

Evidence: FY 2004 Performance Goals for ICDBG include: reduce ICDBG grant balances for 1997-2001 grants; track ICDBG reporting on annual performance to achieve 90% reporting rate; create jobs through economic development/micro enterprise grants; and provide training to grantees to improve program performance. Other measures currently tracked include number of housing rehab and public facility units completed. New output measures to be reported for the 2004 grant awards include: a) square feet for any public facility; b) number of education or job training opportunities provided; c) number of homeownership units constructed or financed; d) number of families proposed to be assisted with a drug-elimination program, or with a program to reduce or eliminate health related hazards; e) several efficiency/cost per unit measures.

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

Explanation: Baselines and targets have been established for most measures.

Evidence: Specific quantifiable goals have been established for each performance measure and reporting requirements have been established for the Field Offices. See measures tab.

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

Explanation: The ICDBG NOFA requires the identification of measures and the applicant to evaluate the specific benchmarks, outcomes and/or goals of the project and to report annually. ONAP will beging consulting with tribes in September 2004 on a number of regulatory changes, including the addition of more detailed performance measures and reporting in order to clearly document grantees progress. The goal is to have regulatory changes published by the end of FY 2005.

Evidence: The NOFA requires the identification of measures and benchmarks, outcomes and goals of each project and the ICDBG regulations require annual reporting on these goals.

Are independent 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: ONAP has requested that the Office of Policy, Development and Research add the ICDBG program to its research agenda for Fiscal Year 2005 in order to provide an independent evaluation. We expect this study to take approximately 12-18 months. The evaluation method will provie the most rigorous evidecne of the program's effectiveness that is appropriate and available. It will also examine the underlying cause and effect relationship between the program and achievement of performance targets. Finally, the evaluation will include recommendations on how to improve the program's performance.

Evidence: HUD's Program Evaluation Division in the Office of Policy, Development and Research has stated that, "PD&R will include an evaluation of ICDBG as one of the studies to be considered for FY 2005 funding. Whether this evaluation is begun and its exact scope are subject to available funding and other demands on the Research and Technology budget. ONAP and PD&R would design this evaluation to develop reliable information on the effects of ICDBG spending."

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: ONAP has included new measures into the 2006 Budget documents as well as Annual Performance Plans.

Evidence: ONAP has four performance measures in place that measure the current goal on job creation under economic development, program expenditures, program reporting and training. Performance measures will be incorporated in to the FY06 budget for Community Planning and Development.

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

Explanation: ONAP has worked for the last two years in developing meaningful goals and objectives. This Office continues to work on developing a database which will provide more detail on accomplishments of our grantees so that we can expand on performance measures and ensure program effectiveness. After consultation with the tribes, revised regulations will be published and it is planned to develop additional performance measures related to the Department's Strategic Plan in FY 2005 and 2006.

Evidence: ONAP has worked over the past two years to develop an Access Database to assist the Office when reporting on ICDBG performance measures. In addition, the ICDBG NOFA for FY04 will make several changes to address project viability and project outcomes. Rating Factors will require applicants to demonstrate quantitatively that the proposed project produces outputs and outcomes that are critical to the viability of the community.

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: ICDBG regularly uses data submitted by grantees to improve performance and increase accountability.

Evidence: Staff review a variety of information submitted by program partners including real-time disbursement data; implementation schedule, expenditure of funds, and grantee assessments; performance information; remote and on-site monitoring reviews. Drawdowns can be suspended when performance information indicates deficiencies. In FY04, funds were suspended for 63 grantees due to reporting failures, program deficiencies and environmental concerns. Of the 403 active grants, 63 (16 percent) had funds suspended.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: HUD managers are rated for performance based upon the Performance Accountability and Communication System (PACS) and the Leadership Development and Recognition System (LDRS). Under this system, the elements used to rate a manager's performance are linked to the Department's GPRA goals.

Evidence: Program managers are evaluated based on the quality of oversight and performance. Under this system, the elements used to rate a manager's performance are linked to the Department's GPRA goals. Ratings, promotions and monetary awards are appropriate to the manager's accomplishments, or lack thereof.

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

Explanation: Unobligated balances or carry-over in 2003 was $80 million. Intended use of funds is verified by staff review of ASER and monitoring efforts. Funds are recaptured if funds are not obligated timely and spent appropriately. Grantees have lost partial or full funding for not complying with requirements of grant agreements and regulations. Cost, implementation and performance results also affect evaluation for future grants in the competitive process. HUD requires grantees submit, and staff review, regular financial and implementation reports on their progress towards achieving the performance outcomes and implementing corrective action. HUD has procedures for risk assessments and on-site and remote monitoring.

Evidence: A review of ICDBG monitoring for FY02 and FY03 showed that 28 grantees were monitored in FY02 and 15 findings related to ICDBG resulted from the monitoring. In FY03, 30 grantees were monitored and 60 findings resulted from the monitoring visits related to ICDBG. The FY 2003 Budget was signed February 20, 2003. HUD received its allotment for ICDBG March 31, 2003. The FY 2003 NOFA for ICDBG was not published July 16, 2003 and awards were made in January/February 2004, which explains the carryover balances. Grantees subject to A-87 Cost Principles and A-133 Audit Requirements. Beginning in 2005, the ICDBG NOFA will be published with the HUD SuperNOFA.

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

Explanation: Competitive sourcing and cost comparisons are required in competitive process. As part of monitoring efforts, HUD reviews procurement practices. After tribal consultation and regulatory changes are completed, HUD will implement IT improvements and provide technical assistance, support, and training to improve project management and accountability. HUD has identified changes that will improve data quality and make use of cost per unit data that will be part of the consultation process. HUD has incorporated incentives for performance, cost efficiencies and the use of innovative technologies into the competitive process.

Evidence: The rate of use of funding can serve as a proxy for an efficient and productive program and signal problems. HUD APP measure 4.2.2 tracks the disbursement of ICDBG for 1997 through 2001 with a goal of reducing the undisbursed balances by 40% from 9-30-03 (75,624,674). Disbursement decrease as of 5-4-04 was 36% ($47,884,234). The FY 2003 NOFA includes a section on incentives to incorporate performance measures (Rating Factor 1 and 5(b)), cost efficiencies and innovative technologies (Rating Factor 3(1)and (2)). In 2001, the cost per public facility building was $621,125; the cost per housing unit rehabilitated was $29,107; and the cost per job created was $1,166.

Does the program collaborate and coordinate effectively with related programs?

Explanation: Tribes often use ICDBG to fill programmatic gaps not covered by other Federal, State, or local programs. For example, tribes may receive funding for operating a variety of social programs but ICDBG can provide funds for the facility. BIA HIP funds, IHBG and ICDBG are combined to fund housing rehabilitation programs. ICDBG funds may build tertiary roads servicing housing or service developments and are combined with BIA/DOT Road Program funds that fund more major road development. Economic development projects funded by ICDBG often receive tribal funds to developed community facilities and economic development projects. HUD also participates in joint training with other funding entities to address grantee needs.

Evidence: The ICDBG NOFA awards 13% of the competitive points based on leveraging, comprehensiveness and coordination with other programs. A concrete example of this funding is the Winnebago Tribe, which was funded for economic development under ICDBG. Additional funding for the development of the commercial portion of a mixed use subdivision was funded with a RHED grant ($400,000), construction loan of approximately $1.5 million, an Administration for Native Americans grant of $70,000 and an SBA contract of $250,000.

Does the program use strong financial management practices?

Explanation: All participating tribes are required to have adequate financial accounting systems and HUD staff review financial reports and LOCCS reports for monthly and annual expenditure of funds. HUD OIG staff audits selected grantees and HUD Area ONAP staff monitor grantees annually in accordance with risk assessment model. HUD has incorporated incentives for strong financial management practices into the competitive NOFA process. The risk assessment analysis is conducted annually and considers: size of the grant and amount disbursed; most recent monitoring visit; delinquent audit reports; open unresolved monitoring or audit findings; and most recent audit report. Recipients are monitored at least once every five years (higher risk grantees more often).

Evidence: Drawdowns can be frozen when performance information indicate deficiencies. For example, the FY02 Standing Rock Tribe's grant was frozen for failure to submit ASER. For the last four fiscal years, $8,478,877 has been recaptured from 43 grants. Since 9-30-03, grantees have decreased their account balances by 36 percent. In FY03, 28 of 280 appliants (10%) were not awarded ICDBG projects because they could not demonstrate substantial capacity including adequate financial systems. In FY02 and FY03, 58 grantees were monitored, which resulted in 75 findings related to ICDBG (approximately 18% of grantees were monitored). A review of audits required under the Single Audit Act revealed 205 audits of ICDBG in FY01-02 with 94 ICDBG related findings (approximately 19% of grantees had at least one audit finding).

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

Explanation: HUD has identified deficiencies in program management and performance and taken several steps to improve the grant award and implementation processes. Deficiencies included the fact that Grants Management and Evaluation functions were not separated. Technical assistance was in conflict with the HUD Reform Act. Training was not equally provided and processing not clearly defined across regions and within regions. Reviewer documentation on applications was not trackable by uninformed reader. NOFA did not evaluate applicant capacity and performance.

Evidence: The NOFA has been restructured to emphasize program performance and accountability. NOFAs prior to FY01 did not consider the capacity of the applicant and the extent of comprehensiveness or coordination with other programs in evaluating application. Since FY01, between 30 and 35 of the 100 points have been dedicated to the applicants capacity and performance. Applicants must now show sufficient level of capacity including managerial, technical and administrative capability and past performance to be funded. Also, risk assessment system has been implemented that supports grantee reviews, risk analysis and monitoring visits (see GE BP Guidelines). An IT system has been developed that tracks findings, corrective actions, sanctions, and dollars recovered (Access database).

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

Explanation: HUD publishes its NOFA for public response with a consistent application review process and clear criteria for over 98% of ICDBG funds (this will become 100 percent in 2004). The remaining $1.3 million was awarded by the Secretary according to HUD regulations for Imminent Threat Grants. Awards published in Federal Register and rating comments available to the public. Changes have been made to give higher consideration to first-time grantees.

Evidence: The ICDBG NOFA has a nationally consistent application review procedures and criteria. HUD also developed a nationally standardized training for reviewers and applicants on the application and implementation process. All potential applicants have been notified regardless of prior participation. Ninety-seven percent of funds are awarded competitively. Selections are announced annually in Federal Register and rating and ranking comments and scores available to public. The NOFA encourages new grantees to apply, but due to the limited number of eligible applicants grantees are often funded periodically.

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

Explanation: The ICDBG Program has several levels of oversight that provide information about grantee activities. HUD reviews data on funds received and disbursed quarterly and LOCCS reports are reviewed monthly to monitor drawdown and disbursement activity and provide technical assistance to grantees. Access data system tracks audits, Release of Funds, amendments, pre-award conditions and close-out activity. Grantees subject to A-133 audit requirements review, track and assist in resolving audit findings. HUD reviews Annual Status and Evaluation Reports (ASER) to determine if goals established in the implementation schedule are being achieved.

Evidence: Performance Measure 4.3.9 tracks the ASER submission rate with a goal of 90% reporting. Currently, the ASER reporting rate is 85% overall with three Area ONAPs having a reporting rate of 90% or higher. Performance Measure 4.2.2. tracks ICDBG expenditures of funds in order to reduce grant balances and ensure funds are distributed and expended in a timely manner. Based on a risk assessment process, 28 of 116 ICDBG grantees were monitored in FY02 and in FY03, 30 of 165 grantees were monitored.' 34 grantees are scheduled for monitoring in FY04.

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: HUD collects data from ICDBG communities and publishes this data on the World Wide Web and in reports.

Evidence: HUD collects information on performance measures including disbursements, ASER reporting, grantee implementation training and job creation. This information, in aggregate form, will be posted in a transparent form on an easy access World Wide Web site for FY04. Project descriptions by tribes and photos (as available) will also be posted on the web in FY04. Once consultation occurs and ASERs are restructured, ASERs by tribes will be posted on the Web. HUD also published Best Practices in 2001 and an Annual report in 2001 addressing ICDBG grantee activity. HUD is working on a new report scheduled for release in the 1st quarter of 2005.

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

Explanation: New outcome measures have been proposed and baselines are under development. However, no long-term outcome measures are currently in place.

Evidence: ONAP is working to develop baselines for its proposed outcome measures. It's current long-term measures are more focused on outputs.

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

Explanation: ONAP has established targets through applications of several performance measures that demonstrate progress toward the program's purpose. For example, the number of jobs created, housing units rehabilitated, or public facilities completed has is directly related to a community's viability. Annual performance targets have largely been met.

Evidence: ONAP has achieved several goals and is on track to meet others, based on data from May 2004. ONAP set a target to create 198 jobs based on approved economic development applications in FY01. Funding from the FY01 grant year created 300 jobs, exceeding the target of 198. Three ICDBG measures focus on HUD's Strategic Goal of Embracing High Standards of Ethics: reduce outstanding balances by 40% (currently at 36% reduction; decrease of $28 million); grantees reporting rate is 90% by 9-30-04 (currently at 85%), and 8 trainings have been conducted to improve program performance (versus six scheduled). ICDBG has also largely met short-term output targets for FY00 and 01 grantees regarding public facility buildings and housing units rehabbed. See measures tab.

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

Explanation: Data on increasing or level outputs relative to the flat funding is needed to demonstrate improved efficiencies. The program has not regularly set targets for performance. Evaluations or studies are not availabe on the long-term effectiveness or efficiency of this program. ONAP has taken Program management processes and procedures were standardized to ensure consistent national application review and grant implementation.

Evidence: Reorganization in Program management clearly outlined responsibilities for program management and monitoring, created consistent national business procedures (see GE and GM Business Process Guidebooks) and introduced performance and capacity factors into the competitive process (see FY 2003 NOFA Rating Factor 1 and 5) and tracking program performance. Training has been conducted for both staff and grantees on the new business process. Increased used of program funds shows that some program efficiencies may have been achieved (see 4.2), but need to data that shows grantees are more efficiently or effectively producing outputs or outcomes over time.

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

Explanation: The ICDBG Program offers a wide range of eligible activities targeted for Native American communities. A study that examines the extent to which ICDBG funds have made a community more viable or livable has not yet been attempted. ICDBG identifies the most needed projects which were not funded from another source or where funding is not available from some other source; however, the program has been unable to demonstrate the effect funds have had on people's lives or improved the surrounding community through performance measures or an evaluation.

Evidence: ICDBG has not yet been able to quantify its ability to impact the outcomes of Native American families or communities. Other programs, such as the HHS Indian Health Service program, are able to quantify how their program has changed individuals lives with the following measures: 1) reduced years of productive life lost; 2) control blood sugar levels in diabetics; and 3) decrease in unintentional injury mortality rates. In many ways it is more difficult to quantify the effects of common ICDBG projects such as public facilities (66 of 129 projects funded in FY03) and infrastructure projects (34 of 129 projects funded in FY03). Private financing of public facilities and infrastructure projects in Indian country is almost nonexistent and ICDBG funds are some of the few available to accomplish larger scale construction of facilities or rehabilitation.

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

Explanation: Currently, no comprehensive evaluation on the program exists. However, ONAP is working with the Office of Policy, Development and Research to provide another independent evaluation to determine program effectiveness.

Evidence: Individual audits are available for ICDBG grantees.