We evaluated HUD’s September 2009 response to questions posed by the Recovery Accountability and Transparency Board’s survey of staff resources dedicated to American Reinvestment and Recovery Act (ARRA).  We wanted to know if the reported number of HUD contract and grant personnel responsible for ARRA funding and oversight could be validated and relied on for public disclosure.

The full-time equivalent (FTE) staffing levels submitted in response to the Board survey could not be validated.  The reported FTE staffing levels reflected “informed estimates” by headquarters program management of ARRA activities.   Documentation was not available to support the estimates because HUD does not track workforce time and activity directly, pay period by pay period.  A comparison of FTE estimates from the survey for the 3rd quarter of FY 2009 to ARRA activity reported in HUD’s Total Estimation and Allocation Mechanism for the same period disclosed material and unexplained differences in the staffing data reported by the Office of Community Planning and Development (CPD) and the Office of Public and Indian Housing (PIH).  CPD and PIH are responsible for awarding and monitoring $11.26 billion (83 percent) of HUD’s $13.62 billion in Recovery Act funding.

HUD’s oversight of Recovery Act activities can be improved through implementation of a verifiable process to account for staff time.  A documented count of FTEs provides information to senior management for use in decision making concerning HUD’s responsibilities under ARRA.  It also serves as a control process consistent with the guidelines set out in Office of Management and Budget Circular A-123.  Further, any future responses to ARRA requests should be supported by information that can be validated.