GAO Report Examines Implementation of Treasury’s ERA Program

New research published by the U.S. Government Accountability Office (GAO) examines factors that affected the timeliness of the U.S. Department of the Treasury’s (Treasury) Emergency Rental Assistance (ERA) Program payments and grantee spending, as well as the impact of Treasury’s reallocation of excess ERA funds and trends in demographic and payment data. The report finds that limited staff and technology resources, unclear program guidance, and several other factors slowed the distribution of ERA. The report also finds that reallocations were unable to correct disparities in ERA1 allocated per low-income household. The report recommends that Treasury collect and publish complete and accurate ERA program data as quickly as possible.

Researchers at the GAO identified spending trends and factors that affected the timeliness of ERA payments based on Treasury ERA data, interviews with 21 ERA grantees, and in-depth analysis of 127 out of 140 program improvement plans. They also analyzed the impact of the reallocation of excess ERA funds based on agency documentation (including grantees’ requests for reallocation), interviews with Treasury officials, and Treasury ERA reallocation data. Finally, they assessed Treasury’s data collection efforts and trends in ERA recipients and grantees using program payment and demographic data.

The GAO identified seven factors that slowed the distribution of ERA. By the end of May 2021, nearly one-quarter of ERA grantees had not yet made any payments. Limited staff and technology resources, difficulty collecting documentation to determine eligibility, unclear program guidance and limited technical assistance, local legislative involvement, limited landlord participation, overlapping grantee jurisdictions, and mismatches between funding allocations and local needs were factors that slowed ERA distribution by grantees.

The report also found that the original ERA1 allocations did not align with the needs of low-income renters by state and that reallocation was insufficient to correct such state-by-state disparities. Due to Treasury’s preference for reallocating excess funds within states rather than between states, disparities by state in the allocation per low-income renter persisted after reallocation: for example, approximately $4,100 was available per low-income renter in Alaska after reallocation, compared to about $740 in New York. Further, city- and county-level grantees were constrained by pools of excess funds available in their states. Requests for reallocation were fully funded when excess funds were available in the state pool, but only partially funded if funds were not available through the state pool. Thus, some cities and counties received additional ERA1 funds despite relatively low need compared to other localities across the country or despite having a relatively poor ability to spend.

The GAO recommends that Treasury improve its data collection and reporting processes by expediently collecting complete and accurate data and publishing complete ERA program data. Disaggregated demographic data for 44% to 55% of households served were missing in the first three quarters of 2021. Further, GAO also found inconsistencies in data necessary for calculating application-funding data and other data anomalies. The available data suggest that ERA reached very low-income and rent-burdened households. Eighty-five percent of households served in the last quarter of 2021 had very low incomes, and counties with greater median gross renters and shares of rent-burdened households were associated with greater number of ERA payments and higher average payments per household.

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