OFFICE OF
THE INSPECTOR GENERAL

SOCIAL SECURITY ADMINISTRATION

HOMELESS OUTREACH PROJECTS
AND EVALUATION
DEMONSTRATION PROJECT

July 2010

A-03-09-19073

AUDIT REPORT

Mission

By conducting independent and objective audits, evaluations and investigations, we inspire public confidence in the integrity and security of SSA’s programs and operations and protect them against fraud, waste and abuse. We provide timely, useful and reliable information and advice to Administration officials, Congress and the public.

Authority

The Inspector General Act created independent audit and investigative units, called the Office of Inspector General (OIG). The mission of the OIG, as spelled out in the Act, is to:

 Conduct and supervise independent and objective audits and investigations relating to agency programs and operations.
 Promote economy, effectiveness, and efficiency within the agency.
 Prevent and detect fraud, waste, and abuse in agency programs and operations.
 Review and make recommendations regarding existing and proposed legislation and regulations relating to agency programs and operations.
 Keep the agency head and the Congress fully and currently informed of problems in agency programs and operations.

To ensure objectivity, the IG Act empowers the IG with:

 Independence to determine what reviews to perform.
 Access to all information necessary for the reviews.
 Authority to publish findings and recommendations based on the reviews.

Vision

We strive for continual improvement in SSA’s programs, operations and management by proactively seeking new ways to prevent and deter fraud, waste and abuse. We commit to integrity and excellence by supporting an environment that provides a valuable public service while encouraging employee development and retention and fostering diversity and innovation.

MEMORANDUM

Date: July 2, 2010 Refer To:

To: The Commissioner

From: Inspector General

Subject: Homeless Outreach Projects and Evaluation Demonstration Project (A-03-09-19073)

OBJECTIVE

Our objective was to determine whether the Social Security Administration (SSA) had appropriate oversight and monitoring controls for the Homeless Outreach Projects and Evaluation Demonstration Project (HOPE). In addition, we determined whether
(1) expenditures for HOPE were allowed, supported, and in accordance with the grant’s terms and (2) grantees accomplished the grant objectives.

BACKGROUND

Congress provided SSA with about $24 million to conduct outreach and application assistance to people who were homeless and other under-served populations. SSA used the funds to establish HOPE in support of the Presidential initiative to end chronic homelessness within 10 years. HOPE’s goals were to (1) assist eligible, chronically homeless individuals in applying for Supplemental Security Income (SSI) and Social Security disability benefits and (2) demonstrate the effectiveness of using skilled medical and social service providers to identify, engage, and assist homeless individuals with disabling conditions to file for benefits within current policy.

In May 2004, SSA awarded 34 grants, totaling approximately $18 million for a 4-year period, to public and private organizations for HOPE. In November 2004, SSA awarded an additional seven grants, totaling about $3.3 million. The 41 grantees were required to provide outreach, support services, and benefit application assistance to chronically homeless adults and children. In addition, HOPE grantees could perform optional activities including presumptive disability screening, pre-release assistance for institutionalized individuals with disabilities, representative payee services, employment interventions, and electronic services to file for benefits. SSA also required that HOPE grantees work with a contractor to independently evaluate HOPE’s outcomes, impacts, and benefits.

SSA expected the 41 grantees to effectively identify people who were chronically homeless so they could receive the assistance and care they needed. In addition, SSA expected that information and technical assistance the grantees received from SSA regional and disability determination services (DDS) employees would increase the efficiency of the disability application process for claimants. In this way, SSA would see a reduction in disability case processing time and denials for initial claims from individuals who were eligible for disability benefits.

Grant Process

SSA’s Office of Acquisition and Grants (OAG) is responsible for processing grant applications and monitoring them once they are awarded. OAG’s monitoring duties include reviewing quarterly progress reports, reviewing quarterly and final Financial Status Reports (FSR), making determinations on re-budgeting grant funds, reviewing requests for carryover funds, conducting necessary site visits, and closing out the grant at the end of an award period.

Once a grant is awarded, OAG requests that SSA’s Office of Finance (OF) allocate funds to an account to fund activities. OF sets up an account in which all grant funds for a grantee are allocated by Fiscal Year (FY). OF processes monthly reimbursement requests from the grantees and makes payments. A grantee can choose to either receive advanced payments or request reimbursement.

SSA’s Office of Program Development and Research (OPDR) was responsible for designing, implementing, and evaluating HOPE. OPDR’s monitoring duties included reviewing quarterly progress reports, conducting necessary site visits, addressing program issues and concerns, and ensuring grantee acceptance and compliance with the grant’s terms and conditions. Furthermore, as part of HOPE, SSA provided the grantees information on its disability programs and application procedures. It also provided a regional/field office liaison and a State DDS liaison, who were responsible for offering grantees a range of technical assistance.
To perform our analysis, we reviewed relevant Federal guidance on grant management, SSA policies, and grant awards for the 41 grantees. Furthermore, we conducted a detailed review of 11 (27 percent) of the 41 grantees who received approximately $5.8 million in grant awards. We sampled their direct costs, payroll, indirect costs, and matching costs incurred in 2004 through 2009 to determine whether (1) grantees’ expenditures were allowed, supported, and in accordance with the terms of the grant award and (2) grantees accomplished the grant objectives. Finally, we evaluated the results of HOPE. See Appendix B for details on our scope and methodology.

RESULTS OF REVIEW

Several grantees for HOPE did not meet one of the project’s objectives. Each grantee was expected to enroll about 200 eligible chronically homeless individuals and assist them with Social Security Disability Insurance or SSI program application process. In total, the HOPE grantees were expected to enroll about 8,200 chronically homeless individuals. Although the 41 grantees had reported enrolling 10,500 chronically homeless individuals, we could only verify that 7,243 individuals (69 percent) had actually filed an application for Social Security benefits. For the remaining 3,257 enrollees (31 percent), we could not verify that an application had been filed for 1,845 enrollees, the grantees did not submit a Social Security number (SSN) for 1,184 enrollees, and the SSNs provided for 228 enrollees were invalid.

Additionally, SSA hired a contractor to conduct an interim evaluation of HOPE to determine its outcomes, impacts, and benefits. We found grantees did not always provide the contractor with the necessary information to assess improvements in the enrollees’ quality of life. For example, grantees only provided data on the living situations for 655 of the 3,055 enrollees who were included as part of the evaluation. Therefore, the contractor was unable to assess the living situations for the remaining 2,400 enrollees.

Furthermore, SSA’s oversight and monitoring of the 41 grantees could have been improved. We question $118,566 in grant funds awarded to 5 of the 11 grantees reviewed because of the lack of adequate supporting documentation. In addition, we question $96,630 in grant funds because 6 of the 41 grantees did not demonstrate that required matching funds were provided. OAG had not found these unsupported costs because they did not conduct site visits to ensure grant expenditures were allowed and supported. In addition, as of January 5, 2010, OAG was at least 284 days late in closing 2 grants in which the grantees had submitted their final reports to the Agency, and 15 grantees were 156 to 516 days late in submitting their final reports to the Agency. As a result, $83,725 in grant funds was not deobligated, and OAG had no support that the grantees had expended $213,977 in grant funds. Finally, we found OF did not deobligate $12,446 in grant funds that a grantee did not use.

ACHIEVING GRANT OBJECTIVES

The 41 grantees were expected to conduct outreach activities to locate homeless individuals with disabling impairments who were potentially eligible for Social Security benefits. Homeless individuals are considered to be enrolled for HOPE when they sign a HOPE consent form, sign an application for SSI or Social Security disability benefits, and file an application with SSA. Each grantee was expected to enroll a minimum of
50 individuals annually by assisting with the application process and assisting the individuals with participating in SSA’s electronic application and case processing. However, the Agency anticipated that some grantees might have difficulty enrolling
50 homeless individuals during the grant’s first year because of the start-up period needed for grantees to train and prepare staff for the project. Therefore, the
41 grantees were expected to enroll slightly fewer than 8,200 individuals during the
4-year grant period. Grantees could enroll individuals who had not yet filed an application for Social Security benefits as well as those whose benefits had been suspended or terminated. However, grantees could not enroll individuals who had applications pending with SSA or those who had already filed for a reconsideration or appeal of a denial or partially favorable decision.

The 41 grantees’ quarterly progress reports indicated that they had enrolled 10,500 individuals who applied for Social Security benefits. However, we could only verify that 7,243 (69 percent) of these reported enrollees had filed an application (see Table 1). Of these 7,243 enrollees, 6,302 (87 percent) were awarded or had been reinstated for SSI or Social Security disability benefits, 891 (12 percent) were denied benefits, and 50 (1 percent) were awaiting a decision. We could not verify that 3,257 of the 10,500 individuals were enrolled because an application was not filed for 1,845 enrollees, and the SSNs provided for 228 enrollees were invalid. Additionally, the grantees did not submit an SSN for 1,184 enrollees (see Table 2). In July 2009, OPDR requested that each of the 41 grantees provide the enrollees’ names, SSNs, and dates enrolled because OPDR had not been tracking this information during the life of HOPE. OPDR had relied on a contractor to track the enrollee information from June 2005 through April 2007. The grantees provided OPDR with enrollee information for 9,316 of the 10,500 enrollees but had not provided any information for the remaining 1,184 individuals. According to data provided by OPDR staff, 3 of the 41 grantees did not respond to their requests for enrollee information. In addition, the grantees’ progress reports indicated some of the 1,184 individuals might have been erroneously counted as enrollees. The progress reports showed that some grantees counted an individual as an enrollee when they signed a consent form to participate in HOPE but did not file a claim for Social Security benefits.
Table 1— Enrollees with Application Filed
Status Total Enrollees Percent
Allowed benefits 6,302 87
Denied benefits 891 12
Awaiting a decision at the time of our review 50 1
Total Enrollees 7,243 100

Table 2— Enrollees without Application Filed
Status Total Enrollees Percent
A claim was not filed for the enrollees 1,845 57
Grantees did not provide enrollee information 1,184 36
Grantees provided invalid SSNs for enrollees 228 7
Total Enrollees 3,257 100

We were unable to use the data provided by OPDR staff to verify whether grantees had enrolled about 200 homeless individuals during the 4-year grant period. However, our review of the grantees’ quarterly progress reports showed that 10 of the 41 grantees had not enrolled 200 homeless individuals during this period. The 10 grantees reported they had enrolled 144 to 197 individuals during the 4-year period. In fact, 5 of the 10 grantees did not enroll 50 individuals for at least 3 of the 4 grant years. For example, a grantee in Michigan enrolled 170 individuals during the 4-year grant period: 17 in year 1; 21 in year 2; 96 in year 3; and 36 in year 4. Of the 10 grantees, 7 had indicated they were unable to meet the expected enrollment number because of certain impediments. For example, 2 of the 10 grantees provided services in Louisiana, and they did not meet the minimum expectation because the homeless were displaced by Hurricane Katrina. Five grantees reported that sources for recruiting potential enrollees were no longer available, they had difficulty maintaining contact with potential enrollees (that is, prisoners), or they had difficulty due to an unexpected move to a different location. SSA found these to be plausible explanations for not meeting the expectations set forth in the grant award. The remaining three grantees did not indicate why they did not meet the requirement.

SSA’s demonstration projects are to provide evidence of the feasibility and effectiveness of a new approach or practice. Because SSA did not discover any policy barriers for the homeless during HOPE, it does not envision changing its current policies and procedures for the homeless. However, SSA continues to conduct outreach and support initiatives that serve the homeless. For example, SSA supports the SSI/SSDI Outreach Assistance and Recovery Technical Assistance Initiative (SOAR) sponsored by the Departments of Health and Human Services, Housing and Urban Development, Labor, and Veterans Affairs. The goal of SOAR is to help States and communities increase access to SSI and SSDI for homeless people with mental illnesses and/or co-occurring substance use disorders. According to OPDR staff, many of the HOPE grantees have built off their HOPE experience and are now participating in SOAR or have found other ways to continue providing outreach and assistance to the homeless.

EVALUATION OF HOPE

In September 2004, SSA hired a contractor to provide an interim evaluation of the outcomes, impacts, and benefits of HOPE. The interim evaluation was used to determine the impact training had on the quality of assistance the grantee provided to disability applicants. SSA was particularly interested in achieving such outcomes as reduced processing time and reduced denials for claims from individuals who would be eligible for benefits under SSA’s rules. SSA was also interested in the degree to which the assistance the grantees provided the homeless improved their quality of life, particularly in attaining stable housing. The contractor analyzed the data collected to compare HOPE grantee outcomes to two groups of agencies that provided similar services to people who were chronically homeless and disabled, and the agencies were located in close proximity to the grantees but did not receive HOPE funding.

The September 2007 contractor’s evaluation showed that HOPE grantees did not always provide the contractor with the necessary information to assess improvements in the quality of life for enrollees. We found that although the original 34 grantees had been expected to enroll at least 5,100 individuals as of May 2007, data for only 3,055 enrollees (60 percent) could be used for the evaluation. The contractor could not evaluate data for 2,045 enrollees because either an initial disability determination had not been completed or an application had not been filed for 1,445 enrollees, and the grantees did not provide valid consent forms for 600 enrollees, allowing personal information to be disclosed to the contractor. Additionally, the grantees only provided

data on the living situations for 655 of the 3,055 enrollees. Therefore, the contractor was unable to assess improvements in the quality of life for the remaining 2,400 enrollees.

Based on the 3,055 enrollees, the contractor had concluded HOPE grantees were able to achieve a quicker time for determination than for the 2 separate comparison groups. For the HOPE grantees, determinations on the allowance and denial of Social Security benefits were made on average in 4.9 months as compared to the other two groups whose determinations were made on average in 5.7 months (see Table 3). Thus, HOPE grantees received a determination almost a month earlier than the two groups.

Table 3 – Comparison of Determination Rate
Average Months to Determination Difference Compared to HOPE Grantees
HOPE Grantees 4.9
Group 1 5.6 -0.7
Group 2 5.8 -0.9
All Groups 5.7 -0.8
Source: McCoy, Marion L., Cynthia S. Robins, James Bethel, Carina Tarnow, and William D. Frey. 2007. Evaluation of Homeless Outreach Projects and Evaluation (HOPE). WESTAT: Rockville, MD

In addition, the contractor concluded that the efficiency of the HOPE grantees to achieve a higher disability allowance rate for their enrollees over the two groups was not demonstrated because the difference was not statistically significant. As shown in Table 4, the HOPE grantees had a 41-percent allowance rate while the two groups had a 47-percent allowance rate, a difference of 6 percent. Therefore, the comparison agencies had a slightly higher allowance rate. However, the evaluation indicated there might have been an uneven implementation pattern among the HOPE grantees that could have affected the allowance rate. Based on visits to 5 of the 34 grantees, the contractor found 3 grantees reported enrolling anyone who met the definition of “chronically homeless” and claimed to have a disabling condition, while 2 grantees used a stricter criteria to avoid individuals who might have tried to “scam the system.” The evaluation did not discuss the two groups’ methodologies for enrolling homeless individuals.

Table 4 – Comparison of Allowance Rates
Allowance Rate Difference Compared to HOPE Grantees
HOPE Grantees 41%
Group 1 39% -2%
Group 2 58% 17%
All Groups 47% -6%
Source: McCoy, Marion L., Cynthia S. Robins, James Bethel, Carina Tarnow, and William D. Frey. 2007. Evaluation of Homeless Outreach Projects and Evaluation (HOPE). WESTAT: Rockville, MD

SSA OVERSIGHT AND MONITORING OF HOPE

We found OAG was monitoring the HOPE grantees by making determinations on
re-budgeting grant funds, reviewing requests for carryover funds, and working closely with grantees to resolve problems. However, OAG’s oversight and monitoring of the grantees could have been improved. We question $118,566 in grant funds awarded to 5 of the 11 grantees reviewed because of the lack of adequate supporting documentation. In addition, we question $96,630 in grant funds because 6 of the
41 grantees did not demonstrate that required matching funds were provided. OAG had not discovered these unsupported costs because it did not conduct site visits to ensure grant expenditures were allowed and supported. In addition, as of
January 5, 2010, OAG was at least 284 days late in closing 2 grants in which the grantees had submitted their final reports to the Agency, and 15 grantees were 156 to 516 days late in submitting their final reports to the Agency. As a result, $83,725 in grant funds was not deobligated, and SSA had no support that the grantees had expended $213,977 in grant funds. Finally, we found OF did not deobligate $12,446 in grant funds not used by a grantee.

Unsupported Grant Expenditures

Financial records, supporting documents, statistical records, and all other records pertinent to a grant award must be retained for 3 years from the date of submission of the final expenditure report. We found 5 of the 11 grantees reviewed were unable to provide documentation to support the $118,566 in expenditures (see Table 5) related to computer equipment, supplies, travel, and administrative costs. For example, a grantee in Indiana could not provide supporting documentation for $81,645 of the $511,605 in grant award funds. According to the grantee, they could not produce documentation to support the expenditures because the computer used to track the financial data for the grant was destroyed in 2008. Another grantee in Connecticut could not provide documentation or show physical evidence for the purchase of 17 laptop computers, modems, and scanners totaling $19,550.

Table 5 - Unsupported Expenditures
State of Grantee Type of Unsupported Expenditures Amount Unsupported Expenditures Percent of Award Total HOPE Award
Connecticut Supplies $19,550 4.0 $550,000
New York Travel and Supplies $715 0.2 $412,500
District of Columbia Consulting and Supplies $1,745 0.3 $550,000
Florida Administrative Expenses1 $14,911 3.0 $550,000
Indiana Supplies $81,645 16.0 $511,605
Total $118,566 $2,574,105
Note: (1) The grantee’s general ledger identified these expenses as administrative.

Matching Funds Requirement

HOPE required matching funds from grantees to broaden the impact it would have on the homeless population. Our review of the grantee’s final FSRs and financial records showed that 6 of the 41 grantees did not substantiate that they provided the required matching share of $96,630 (see Table 6). The grant award required that the grantees provide a matching share that equals a minimum of 5 percent of the total project costs. The matching share is calculated using the following formula: Federal share divided by .95 equals total project costs. The matching share equals the total project cost minus the Federal share. Since the six grantees did not demonstrate that the required matching funds were provided, we question $96,630 in grant funds.

Table 6—Unsupported Matching Share
State of Grantee Total Federal Share Required Matching Share Actual Matching Share Questioned Costs
Connecticut $550,000 $28,947 $0(1) $28,947
Indiana $511,605 $26,927 $0(1) $26,927
New York $400,054 $21,055 $0(1) $21,055
California $548,484 $28,868 $12,983 $15,885
Massachusetts $445,423 $23,443 $21,222 $2,221
Oregon $377,206 $19,853 $18,258 $1,595
Total $96,630
Note: (1) During our site visits, the grantees could not provide support for any of their matching share.

Closing of Grants

We found that SSA failed to close two grants although the grantees had submitted their required final reports to the Agency on July 21, 2008 and March 21, 2009, respectively. Therefore, as of January 5, 2010, OAG was 284 and 533 days late, respectively, in closing these grants. As a result, $83,725 in grant funds was not deobligated for one of the two grantees. OAG did not close this grant because it was waiting for the grantee to provide its final indirect cost rate. However, we did not find any evidence that OAG had followed up with the grantee to obtain the final indirect cost rate. According to SSA policy, when the grant period has ended, SSA is required to close the grant to ensure the Government’s interest has been adequately protected. The close-out process requires that SSA obtain and review the grantee’s final FSR and progress report, which are due within 90 days after the grant’s expiration. We believe SSA must take steps to ensure grants are closed timely so Federal dollars can be deobligated when not needed and put to better use.

Submission of Final Reports

As of January 5, 2010, we found 15 grantees had not submitted their final FSRs even though the grants had ended. Of the 15 grantees, 14 had not submitted their final FSRs and 1 had not submitted both their final FSR and progress report. The grantees were between 156 and 516 days late in submitting the final reports. Because the final FSRs were not submitted to OAG timely, there was no evidence that 7 of 15 grantees had expended about $213,977 in grant funds. While OAG had notified the grantees of the requirement to submit the final reports 30 days before the grant expiration date, we found OAG did not always follow up with the grantees to ascertain the reason for delay and obtain a revised submission date, as required by its policy. We believe OAG needs to follow up with the 15 grantees to ensure they submit their final FSRs to the Agency.

Deobligate Grant Funds

We found OF did not deobligate $12,446 in grants funds for a grantee who submitted its final FSR. These funds were not deobligated because OF did not compare the amount of the grant award to the amount drawn down by the grantee. Instead, they relied on the balances reported on the grantee’s final FSRs, which erroneously showed a zero balance. Our comparison of the amount awarded to the amount received showed the grantee had an unobligated balance of $12,446. We informed staff in OF, and they deobligated the $12,446 at the time of our review.

CONCLUSION AND RECOMMENDATIONS

Because the HOPE grantees did not always deliver the performance they were funded to produce by assisting about 8,200 homeless individuals with applying for Social Security benefits, HOPE did not benefit as many homeless individuals as intended. Our review found that the 41 grantees had only assisted 7,243 of the 10,500 reported enrollees with filing a claim for Social Security benefits. We were not able to verify whether an additional 3,257 enrollees had applied for benefits through HOPE. In addition, while we found OAG was monitoring the grantees by making determinations on re-budgeting grant funds, reviewing requests for carryover funds, and working closely with grantees to resolve problems, we believe OAG still needed to increase its oversight and monitoring of the HOPE grantees. Specifically, OAG needed to ensure that grantees submitted the required FSRs and progress reports, which demonstrates whether grant funds were being used effectively and as intended. In addition, OAG needed to ensure that site visits were performed and grants were closed in a timely manner.

Accordingly, we recommend SSA:

1. Require that the five grantees provide adequate support or return $118,566 to SSA.

2. Require that the six grantees provide adequate support for the matching share or return $96,630 in grant funds to SSA.

3. Deobligate $83,725 in grant funds awarded but not disbursed to one grantee.

4. Ensure that grants are closed in accordance with SSA policy.

5. Follow up with the 15 grantees to ensure they submit their final financial and/or progress reports.

6. Improve monitoring of the grants by conducting site visits when warranted so problems are identified and corrective action is taken to help grantees achieve or revise their performance objectives.

7. OAG, OPDR, and OF should work together to enhance the monitoring and oversight of grantees to ensure that grant funds are used appropriately and as intended.

AGENCY COMMENT

SSA agreed with our recommendations. See Appendix F for the full text of SSA’s comments.

/s/
Patrick P. O’Carroll, Jr.

Appendices
APPENDIX A – Acronyms

APPENDIX B – Scope and Methodology

APPENDIX C – Homeless Outreach Projects and Evaluation Demonstration Project Grantees

APPENDIX D – Summary of Sampled Grantees

APPENDIX E – Homeless Outreach Projects and Evaluation Demonstration Project Grantees Core and Optional Functions

APPENDIX F – Agency Comment

APPENDIX G – OIG Contacts and Staff Acknowledgments

Appendix A
Acronyms

C.F.R. Code of Federal Regulations
DDS Disability Determination Services
FY Fiscal Year
FSR Financial Status Report
HOPE Homeless Outreach Projects and Evaluation Demonstration Project
OAG Office of Acquisition and Grants
OF Office of Finance
OIG Office of the Inspector General
OPDR Office of Program Development and Research
SSA Social Security Administration
SSI Supplemental Security Income
SSN Social Security Number
U.S.C. United States Code
Form
Form–269A Financial Status Report

Appendix B
Scope and Methodology
To accomplish our objectives, we:

• Reviewed the Social Security Administration’s (SSA) policies and procedures on grant management, including SSA’s Grant Policy Handbook and Grant Administration Manual.

• Reviewed applicable Federal laws and regulations regarding grant awards as well as Office of Management and Budget Circulars A-21 (Cost Principles for Educational Institutions) and A-133 (Audits of States, Local Governments, and Non-Profit Organizations).

• Reviewed the Evaluation of Homeless Outreach Projects and Evaluation Demonstration Project (HOPE) Final Evaluation Report, October 2007.

• Reviewed the terms and conditions of the grant set forth in the solicitation and award.

• Reviewed the HOPE project applications, Budget Narratives, Financial Status Reports, and Quarterly Progress Reports as well as SSA’s correspondence with grantees.

• Reviewed the 41 grantees to determine whether a Single Audit was performed in Fiscal Year 2007.

• Reviewed allegations of fraud concerning one grantee in Indiana.

• Obtained and reviewed the grant files for all 41 HOPE grantees, which included grant award document, approved budgets, quarterly Financial Status Reports (FSR) (Form-269A), quarterly progress reports, and other correspondence.

• Obtained and reviewed the 41 HOPE grantees’ reimbursement histories from the Social Security Online Accounting and Reporting System.

• Selected 11 grantees for review based on the following criteria:

 each SSA region was represented in the selection;
 grantees who did not meet the HOPE objective of enrolling at least 50 homeless individuals within a grant year; and
 grantees who had the lowest and highest outcome of favorable decisions.

• Conducted 11 site visits and tested samples of grantees’ direct costs, payroll, indirect costs, and matching costs.

• Obtained and reviewed the data extract of enrollee information provided by the grantees in August 2009.

• Reviewed the National Disability Determination Services System, Master Beneficiary Record, and the Supplemental Security Record.

We performed our audit in the Philadelphia Audit Division and at the locations of the 11 sample grantees between April 2009 and January 2010. We determined that data used for this audit were sufficiently reliable to meet our audit objectives. We assessed the reliability of the data by reconciling sample invoices to the selected transactions. In addition, we verified claim data for enrollees to SSA’s records. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix C
Homeless Outreach Projects and Evaluation Demonstration Project Grantees

The Homeless Outreach Projects and Evaluation Demonstration Project (HOPE) is a Social Security Administration (SSA) initiative to assist the chronically homeless. In May 2004, SSA awarded 34 grants, totaling about $18 million, to public and private organizations to provide outreach, support services, and benefit application assistance to chronically homeless adults and children. As of September 2009, the 34 grantees had drawn down about $17.7 million of the $18 million in grants funds.

Count of Grantees State Total
Grant Award Grant Funds Received Start Date End Date Received No Cost Extension (b) Total Reported Enrollees
1 CA $550,000 $550,000 5/1/2004 4/30/2008 394
2 CA $550,000 $547,937 5/1/2004 4/30/2008 224
3 CA $537,130 $537,129 5/1/2004 4/30/2008 215
4 CA $547,401 $547,403 5/1/2004 4/30/2008 223
5 CA $549,595 $549,567 5/1/2004 6/30/2008 Yes 175(a)
6 CA $550,000 $548,484 5/1/2004 4/30/2008 240
7 CA $527,004 $527,003 5/1/2004 6/30/2008 Yes 216
8 CA $550,000 $550,000 5/1/2004 10/31/2008 Yes 309
9 CO $550,000 $540,534 5/1/2004 4/30/2008 571
10 CT $550,000 $550,000 5/1/2004 4/30/2008 238
11 DC $550,000 $490,796 5/1/2004 5/31/2008 Yes 233
12 FL $550,000 $550,000 5/1/2004 4/30/2008 207
13 HI $514,720 $514,720 5/1/2004 10/31/2008 Yes 296
14 KS $481,520 $479,672 5/1/2004 4/30/2009 320
15 LA $549,989 $546,081 5/1/2004 4/30/2009 160(a)
16 LA $550,000 $550,000 5/1/2004 4/30/2008 144(a)
17 MA $550,000 $466,275 5/1/2004 10/31/2008 Yes 154(a)
18 MA $538,063 $538,063 5/1/2004 4/30/2008 219
19 MA $550,000 $550,000 5/1/2004 4/30/2008 271
20 MI $550,000 $538,149 5/1/2004 4/30/2009 170(a)
21 MN $394,194 $393,834 5/1/2004 4/30/2008 226
22 MN $550,000 $535,572 5/1/2004 4/30/2008 312
23 NV $486,640 $486,640 5/1/2004 4/30/2008 431
24 NY $545,897 $492,167 5/1/2004 4/30/2008 197(a)
25 NY $550,000 $550,000 5/1/2004 4/30/2008 220
26 NY $550,000 $528,376 5/1/2004 4/30/2008 195(a)
27 NY $412,500 $400,054 5/1/2004 4/30/2008 187(a)
28 NY $550,000 $550,000 5/1/2004 4/30/2008 227
29 OH $550,000 $550,000 5/1/2004 7/31/2008 Yes 329
30 OR $550,000 $550,000 5/1/2004 4/30/2008 185(a)
31 OR $377,206 $377,207 5/1/2004 4/30/2008 488
32 TX $550,000 $539,812 5/1/2004 4/30/2009 330
33 WA $550,000 $550,000 5/1/2004 8/31/2008 Yes 197(a)
34 WI $550,000 $550,000 5/1/2004 8/31/2008 Yes 238
Total $18,011,859 $17,725,476(c) 8,741
Note: (a) The 10 grantees did not enroll at least 200 homeless individuals during the 4-year grant period.
(b) The grantees were granted an extension without receiving additional grant funds.
(c) Number is higher due to rounding.

In November 2004, SSA awarded an additional seven grants totaling about $3.3 million to private and public organizations. As of September 2009, the seven grantees had drawn down about $3.2 of the $3.3 million in grant funds.

Count of Grantees State Total Grant Award Grant Award Received Start Date End Date Received No Cost Extension Total Reported Enrollees
1 AZ $549,621 $512,271 11/1/2004 10/31/2008 202
2 IN $511,614 $511,605 11/1/2004 10/31/2008 249
3 MA $445,423 $445,423 11/1/2004 10/31/2008 220
4 NC $266,891 $239,666 11/1/2004 10/31/2008 209
5 TX $430,445 $373,696 11/1/2004 10/31/2009 233
6 TX $550,000 $550,000 11/1/2004 10/31/2008 284
7 WI $550,000 $550,000 11/1/2004 10/31/2008 362
Total $3,303,994 $3,182,661 1,759
41 Grand Total $21,315,853 $20,908,137 10,500

Appendix D
Summary of Sampled Grantees

Count State Total Grant Award Unsupported Expenditures Unsupported Matching Funds
1 CT $550,000 $19,550 $28,947
2 NY $412,500 $715 $21,055
3 DC $550,000 $1,745 None
4 FL $550,000 $14,911 None
5 IN $511,614 $81,645 $26,927
6 LA $549,989 None None
7 KS $481,520 None None
8 CO $550,000 None None
9 CA $550,000 None None
10 CA $527,005 None None
11 OR $550,000 None None
Total $5,782,627 $118,566 $76,929

Appendix E
Homeless Outreach Projects and Evaluation Demonstration Project Grantees Core and Optional Functions

Grantees were required to perform the core functions and could choose to perform other optional functions.

Core Grant Activities

• Conduct outreach activities to locate homeless individuals with disabling impairments who are potentially eligible for Social Security benefits. Grantees are expected to enroll at least 50 individuals annually. Grantees may enroll individuals who have not yet filed an application for Social Security benefits as well as those whose benefits are suspended or terminated. Grantees may not enroll individuals who have applications pending with the Social Security Administration (SSA) or those who have already filed for a reconsideration or appeal of a denial or partially favorable decision. Grantees may enroll individuals with whom they had contact before the grant award, if the individual has not already filed a claim for benefits. To be considered a project participant, an individual must be enrolled by the grantee using the reporting mechanism provided by SSA and its evaluation contractor.

• Provide direct assistance to homeless individuals in the Social Security benefit application process.

• Assist claimants with finding necessary documentation for the Social Security benefit application and appeals process, including proof of identity, financial records, and medical records.

• Provide existing medical evidence in the claimant’s medical records.

• Perform any necessary medical examinations, arrange for such examinations, and/or establish a collaborative relationship with an organization that will perform any examinations needed to make a disability determination.

• Assist claimants with attending consultative examinations, when necessary.

• Provide information regarding the effect a claimant’s impairment has on their ability to perform work.

• Maintain contact with the claimant throughout the determination process and help the claimant respond to requests for further information.

• Assist claimants with filing reconsideration requests and appeals.

• Collaborate with, and make referrals to, other organizations to ensure favorable outcomes for claimants and beneficiaries, including working with agencies that provide
o mental health services;
o supportive housing;
o community-based health care services;
o employment rehabilitation services;
o job placement;
o benefit planning assistance and outreach;
o veterans' health benefits;
o substance abuse treatment;
o translation and/or interpreter services; and
o services to parolees and those in work-release programs.

• Assist claimants with participating in SSA electronic application and case processing initiatives.

• Attend training designed to improve the quality of core activities.

• Plan for project continuation when grant funding ends.

Optional Activities: The grantees could use grant funds to perform functions that would help homeless individuals with disabling impairments attain stable supportive housing, recover, attain employment, and use benefits to meet basic needs. Funds could be used to:

• Develop and improve representative payee services.

• Screen claimants for “presumptive disability.” Under SSA program rules, a Supplemental Security Income claimant may receive payments, for up to 6 months, based on a presumption of disability. Grantees who choose to exercise the option to include a presumptive disability element in their project will work with SSA program staff, and local field office and disability determination services representatives, after award, to establish and implement any project-specific procedures that may be deemed necessary by SSA.

• Establish and implement pre-release procedures.

• Improve electronic services and information sharing.

• Develop a work entry/return-to-work program.

Evaluation: Grantees were required to work with the evaluation contractor who conducted an independent evaluation of outcomes, impacts, and benefits of the HOPE projects. The evaluation contractor developed an interactive website to collect evaluation information from the grantees. The grantees were required to use the Website monthly to report enrollee information. The contractor used the Website to track enrollee information from June 2005 through April 2007.

Appendix F
Agency Comment

MEMORANDUM

Date: July 1, 2010 Refer Refer To: S1J-3

To: Patrick P. O'Carroll, Jr.
Inspector General

From: James A. Winn
Executive Counselor to the Commissioner

Subject: Office of the Inspector General (OIG) Draft Report, "Homeless Outreach Projects and Evaluation Demonstration Project" (A-03-09-19073)--INFORMATION

Thank you for the opportunity to review and comment on the draft report. We appreciate OIG’s efforts in conducting this review. We agree with the results of your review and are taking the necessary steps to implement the recommendations.

Please let me know if we can be of further assistance. Please direct staff inquiries to
Candace Skurnik, Director, Audit Management and Liaison Staff, at extension 54636.

Appendix G
OIG Contacts and Staff Acknowledgments
OIG Contacts

Cylinda McCloud-Keal, Director, Philadelphia Audit Division

Carol Madonna, Audit Manager

Acknowledgments

In addition to those named above:

Damon Mahoner, Senior Auditor

Michael Brooks, Auditor

David Domzalski, Auditor

Richard Devers, IT Specialist

Atlanta Audit Division
Chicago Audit Division
Dallas Audit Division
Falls Church Audit Division
Kansas City Audit Division
New York Audit Division
San Francisco Audit Division

For additional copies of this report, please visit our web site at www.socialsecurity.gov/oig or contact the Office of the Inspector General’s Public Affairs Staff Assistant at (410) 965-4518. Refer to Common Identification Number
A-03-09-19073.

DISTRIBUTION SCHEDULE

Commissioner of Social Security
Office of Management and Budget, Income Maintenance Branch
Chairman and Ranking Member, Committee on Ways and Means
Chief of Staff, Committee on Ways and Means
Chairman and Ranking Minority Member, Subcommittee on Social Security
Majority and Minority Staff Director, Subcommittee on Social Security
Chairman and Ranking Minority Member, Committee on the Budget, House of Representatives
Chairman and Ranking Minority Member, Committee on Oversight and Government Reform
Chairman and Ranking Minority Member, Committee on Appropriations, House of Representatives
Chairman and Ranking Minority, Subcommittee on Labor, Health and Human Services, Education and Related Agencies, Committee on Appropriations,
House of Representatives
Chairman and Ranking Minority Member, Committee on Appropriations, U.S. Senate
Chairman and Ranking Minority Member, Subcommittee on Labor, Health and Human Services, Education and Related Agencies, Committee on Appropriations, U.S. Senate
Chairman and Ranking Minority Member, Committee on Finance
Chairman and Ranking Minority Member, Subcommittee on Social Security Pensions and Family Policy
Chairman and Ranking Minority Member, Senate Special Committee on Aging
Social Security Advisory Board

Overview of the Office of the Inspector General
The Office of the Inspector General (OIG) is comprised of an Office of Audit (OA), Office of Investigations (OI), Office of the Counsel to the Inspector General (OCIG), Office of External Relations (OER), and Office of Technology and Resource Management (OTRM). To ensure compliance with policies and procedures, internal controls, and professional standards, the OIG also has a comprehensive Professional Responsibility and Quality Assurance program.
Office of Audit
OA conducts financial and performance audits of the Social Security Administration’s (SSA) programs and operations and makes recommendations to ensure program objectives are achieved effectively and efficiently. Financial audits assess whether SSA’s financial statements fairly present SSA’s financial position, results of operations, and cash flow. Performance audits review the economy, efficiency, and effectiveness of SSA’s programs and operations. OA also conducts short-term management reviews and program evaluations on issues of concern to SSA, Congress, and the general public.
Office of Investigations
OI conducts investigations related to fraud, waste, abuse, and mismanagement in SSA programs and operations. This includes wrongdoing by applicants, beneficiaries, contractors, third parties, or SSA employees performing their official duties. This office serves as liaison to the Department of Justice on all matters relating to the investigation of SSA programs and personnel. OI also conducts joint investigations with other Federal, State, and local law enforcement agencies.
Office of the Counsel to the Inspector General
OCIG provides independent legal advice and counsel to the IG on various matters, including statutes, regulations, legislation, and policy directives. OCIG also advises the IG on investigative procedures and techniques, as well as on legal implications and conclusions to be drawn from audit and investigative material. Also, OCIG administers the Civil Monetary Penalty program.
Office of External Relations
OER manages OIG’s external and public affairs programs, and serves as the principal advisor on news releases and in providing information to the various news reporting services. OER develops OIG’s media and public information policies, directs OIG’s external and public affairs programs, and serves as the primary contact for those seeking information about OIG. OER prepares OIG publications, speeches, and presentations to internal and external organizations, and responds to Congressional correspondence.
Office of Technology and Resource Management
OTRM supports OIG by providing information management and systems security. OTRM also coordinates OIG’s budget, procurement, telecommunications, facilities, and human resources. In addition, OTRM is the focal point for OIG’s strategic planning function, and the development and monitoring of performance measures. In addition, OTRM receives and assigns for action allegations of criminal and administrative violations of Social Security laws, identifies fugitives receiving benefit payments from SSA, and provides technological assistance to investigations.