Accreditation Report
April 1997



Accreditation in Public Housing: A Call for A Study

Council of Large Public Housing Authorities (CLPHA)

National Association of Housing and Redevelopment Officials (NAHRO)


Public housing industry groups have reached agreement that now is a propitious time to conduct
a thorough and comprehensive study of accreditation for public housing to address the issues of
quality, performance, deregulation and remediation. The dramatic downsizing of HUD makes
the need for a study even more urgent. Furthermore, the current evaluation system, the Public
Housing Management Assessment Program (PHMAP), has recently undergone serious review
and criticism from a variety of institutions including the General Accounting Office and even
HUD Secretary Cuomo.

This paper examines the need for changes in the way public housing performance is assessed,
why accreditation should be considered, how other industries use accreditation effectively and its
applicability to public housing. The paper concludes that there is substantial evidence that
accreditation is applicable to public housing and that such an evaluation system would likely
yield positive benefits for the public housing industry. However, the paper also points out that
there are a number of unanswered questions that must be carefully addressed in a study of
applicability of accreditation to public housing.


Public housing authorities (PHAs) across the country own and operate 1.4 million units of low
income housing serving 3.1 million Americans. These 13,000 public housing developments are
located in urban, suburban and rural locations and vary dramatically in size scale and conditions
within PHAs and across PHAs. For years we have debated how to devise and implement an
effective oversight and evaluation system that allows good performers to operate with flexibility
and remedies the problems of poor performers, while continually improving the overall quality
of public housing residents.

Public housing industry groups have reached agreement that it is time to conduct a thorough and
comprehensive study of accreditation for public housing to address the issues of quality,
performance, deregulation and remediation. The dramatic downsizing of the Department of
Housing and Urban Development (HUD), the federal regulatory and monitoring agency for
public housing, makes the need for a study even more urgent.

Furthermore, the current evaluation system, the Public Housing Management Assessment
Program (PHMAP), provides national standardized, quantitative measures of performance, that
most agree falls short of what is truly needed to improve and sustain public housing

The time has come to look to accreditation, effectively used in many other industries such as
health care, hospital facilities, and higher education, as means to develop and enforce qualitative
standards of real estate management performance for public housing. The purpose of this paper
is to examine the need for changes in the way public housing performance is assessed, why
accreditation should be considered, how other industries use accreditation effectively and its
applicability to public housing.

Accreditation in Public Housing Is Not A New Idea

Congress first recommended that a public housing accreditation commission be established in
1983. In the report, the Senate Committee on Banking, Housing, and Urban Affairs
recommended that an accreditation commission be established to "represent housing authorities,
local governments, and low income tenants"
1 and charged with three tasks:

In 1989, Congress established the National Commission on Severely Distressed Public Housing
with the charge to propose a national plan to eradicate severely distressed public housing.

During the next 18 months, the Commission and staff visited public housing developments in
more than 25 cities; held 20 public hearings; consulted extensively with public housing residents;
and conducted thorough interviews with the boards of directors and staffs of PHAs and industry
leaders. In 1992, the Commission issued a final report stating:

The Commission proposes the implementation of a national accreditation system
for public housing, with the purpose of evaluating PHAs based on their
performance, not on their compliance with regulations.
This accreditation system
would not duplicate the HUD functions, but would be completely separate and
independent of the regulatory agency. The Commission feels that an entirely new
system for appraising and assessing management performance is required for
most public housing. This change in the system for reviewing public housing
organizations will not only improve assessments of severely distressed public
housing, but will also result in a sounder method of addressing management
performance throughout the public housing industry.

The Commission recommended that this system be based on industry standards and that current
standards based on regulatory compliance were inadequate to fully evaluate PHA performance.
The goal of an accreditation system as described by the Commission was to evaluate the
efficiency of systems, identify weak areas, and provide recommendations and assistance for
improvements. The Commission further stipulated that the accreditation system be administered
by an entity which is independent of HUD, both in terms of oversight authority and funding.
The accrediting body would be authorized to develop performance standards, would administer a
system designed to provide incentive to PHAs for improving overall performance, basic systems,
and daily operations.

In the intervening years and the publication of the National Commission's report with its
recommendations to pursue an accreditation system for public housing, so there continues to be
considerable interest in public housing accreditation. Last year's H.R.2406 and again this year's
H.R. 2 calls for and Accreditation Board to be set up to evaluate PHAs. H.R. 2, the Housing
Opportunity and Responsibility Act, differs from last year's proposal in that it calls for a study of
accreditation prior to formal implementation of an Accreditation Board. HUD's authorization
bill calls for a Performance Evaluation Board to study accreditation. Public housing industry
groups strongly support a comprehensive study of the relevance of accreditation to public
housing but are opposed to the implementation of a board until the study recommendations are
reviewed and acted on.

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As HUD continues to downsize from an agency of over 13,000 employees to 7,500, the need to
promote greater flexibility for and reliance upon those that are regulated will only intensify. In
the area of public housing, the need could not be more acute. The Public and Indian Housing
(PIH) staff has diminished both in headquarters and in the field and while PIH programs
represent a significant portion of the HUD budget, staff are only a small fraction of the total
HUD staff. The PIH Assistant Secretary has said that one of his greatest challenges is to allocate

a dwindling staff among the many competing issues in his office. PIH is openly discussing fully
deregulating small PHAs, in part, because of diminishing staff capacity. Many functions of PIH
are currently or about to be contracted out to a variety of consulting firms, again in part because
HUD is simply not able to do the work itself.

Furthermore, because HUD staff has historically played the role of regulating and reviewing
compliance, he staff does not reflect the evolving need for property management, asset
management, and mixed-finance development expertise. The dramatic downsizing will
significantly limit HUD's ability to acquire and sustain this type of staff expertise. Much of the
innovation in public housing has come from the industry not the regulator.
5 Much like the
technological changes in health care discussed below, public housing needs an accreditation
system to promote change and improvement.

The current monitoring system for public housing, the Public Housing Management Assessment
Program (PHMAP), is significant in that is the first attempt at using specific indicators to assess
the management performance of PHAs. However, seven years after the National Affordable
Housing Act of 1990 established PHMAP, the system has very serious shortcomings. The GAO
reports, "PHMAP -- HUD's primary tool for measuring housing authorities' performance -- has
been criticized as unreliable, inaccurate, and at times conflicting with good property
6 The principal findings state:
* Field offices' use of PHMAP and related oversight tools has been limited. Field offices
reported that they have not been systematically complying with PHMAP's statutory and
regulatory follow-up requirement for all housing authorities. In 1992, HUD's field offices
entered into 29 percent of the required memorandums of agreement; by 1995, just 18 percent
of the housing authorities that should have been operating under a memorandum of
agreement actually were.
* Scores are increasing, but HUD recognizes database flaws limit program's use. GAO
found missing, inaccurate, and inconsistent data in HUD's primary database for storing
PHMAP scores.
* The questionable accuracy and validity of PHMAP scores limit the program's
usefulness. PHMAP scores are not a generally accepted measure of good property
management. HUD officials, as well as representatives of public housing industry
associations and professional property management consultants, authority's performance.
For example, PHMAP does not include an independent on-site inspection of the condition of
an authority's housing, so it does not same HUD officials and industry representatives also
told GAO that PHMAP does not always allow for extenuating circumstances that can lead to
decisions inconsistent with good property management.

Thus, PHMAP is doubly troubled: it is not an adequate monitoring system and it is not being
adequately used. Again according to GAO, "the impact of a 1995 reorganization of the field
offices' functions and current departmental downsizing continue to influence some offices'

ability to provide technical assistance."8 PHMAP has been greatly improved since its inception
through the work of dedicated public housing professionals -- but it cannot do the job alone. In
addition, PHMAP is a nationally prescribed system, but public housing exists in local
communities -- communities that represent considerable variation. Far more needs to be done to
accurately measure those local variations.

To underscore the deficiency of HUD's current assessment methods, HUD Secretary Andrew
Cuomo, in testimony before the Senate Committee on Banking, Housing and Urban Affairs,
called for the elimination of PHMAP because of its inherent shortcomings. The Secretary
proposes to replace PHMAP with a new Performance Evaluation System with a focus on
physical conditions as well as management systems. The HUD Bill proposes to establish a
Performance Evaluation Board to assist HUD in monitoring PHA performance. The Board
"would consider further improvements to the evaluation system. The improvements to be
considered would include any possible role for peer review, accreditation and placement of more
emphasis on the actual condition of the housing."
9 In addition, the Secretary also expressed
concern that the current proposal to establish an accreditation entity in advance of the results of a
study was premature and ill advised.

Finally, HUD's troubled housing recovery interventions have been uneven at best. In 1979,
HUD established a list of troubled housing authorities. Some authorities have been on the list for
more than a decade. Others come off and on the list intermittently, improving performance for
awhile but unable to sustain improved performance. The complexities of factors contributing to
troubled status as well as local and national political sensitivities have rendered many of HUD's
interventions ineffective. HUD has been slow to react and politically unable to promote change
where it has been needed.

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The advantages of accreditation, examined later in the context of health care and higher
education, such as technical expertise, flexibility of standard-setting, incentives for compliance,
and cost savings are clearly appropriate to the relationship between public housing and HUD. In
fact, a careful reading of the Commission's recommendations for public housing accreditation
parallel these general advantages and address many of the fundamental problems associated with

The advantages of accreditation include:

accreditation process would engage PHAs in the assessment program by requiring them to
conduct a self-assessment using their internally developed goals as an initial measure.
Today, there is universal agreement on the importance of comprehensive planning: H.R. 2, S.
462, and the HUD Bill, all strongly endorse annual plans for PHAs which would serve as the
basis for determining that the PHA is meeting local needs and goals.

Other Accreditation Models and Their Relevance to Public Housing

At this point in time there is strong, persuasive evidence that accreditation is appropriate for
public housing. Moreover, there is evidence that accreditation would be a positive step for the
industry, for HDU, and for the over three million residents in public housing. Accreditation of
PHAs would also have a salutary effect on the nation's cities. In short, accreditation has
innumerable possibilities for improving our public housing stock.

An Accreditation Board, a jury of peers made up of public housing professionals, real estate
experts, government interest and public housing residents, with no political ties might be better
able to create change. Peer review could offer technical assistance, could require report cards
and progress reports, and ultimately call for independent takeovers if needed. If the industry
itself is willing to recognize the need for these changes and is willing to police itself, shouldn't
we at least consider the possibilities?

Accreditation has had a long history in the United States. In the health care field, for example,
private accreditors have, for many years, meditated between government and private institutions
providing health services. The Joint Commission of Accreditation of Health Care Organizations
(JCAHO) perhaps the most well-known and prominent of accrediting programs, established in
the early 1950s, has provided accreditation of hospitals and other institutions that receive
Medicare funds since the inception of the program. However, accreditation in the medical

community goes back far earlier than JCAHO, to the early part of the twentieth century when
advances in medical science and the need to standardize hospital facilities was recognized. In
addition to accreditation in health care there are a variety of other models of institutional
accreditation in other industries, including most notably, education.

As is the case with health care, accreditation in education has spanned much of the last century.
Over the years, a variety of laws in aid of post-secondary education have been enacted providing
aid for programs, capital construction of facilities and institutions, and, of course, financial aid to
students. These federal dollars have been limited to institutions that meet minimum standards.
In fact, today, most post-secondary institutions and program meet eligibility federal funds by
obtaining accreditation form one of the accrediting organizations recognized by the Secretary of

Accreditation in Healthcare

Healthcare has been chosen for a variety of reasons: it is one of the oldest models; there is
considerable evaluation material to rely on; and it represents adequate substitution for direct
public regulation. In short, the federal government in the case of the Department of Health and
Human Services has chosen to protect the public interest not through direct federal regulation,
but through a system of private, peer review. Are there lessons from this model for the
regulation of public housing?

The JCAHO is private, nonprofit corporation that currently accredits over 10,000 healthcare
institutions. Its board is made up of 28 commissioners appointed by the American Medical
Association, the American Hospital Association, the American College of Physicians, the
American College of Surgeons, and the American Dental Association. Other members include
nurses and representatives from the general public. The JCAHO Board meets three times a year
to consider policy matters, adopt new standards, and examine issues as they relate to the
accreditation process. JCAHO has progressively expanded the scope of its accreditation
programs from what exclusively a hospital orientation to include a more broad healthcare focus
including ambulatory care long term care, psychiatric facilities, as well home healthcare
networks (its name changed from the Joint Commission on Accreditation of Hospitals to its
current name in 1987 to accommodate this increased activity). According to one scholar,
JCAHO is the nation's largest and most influential private accrediting organization.

Hospitals accredited by JCAHO are surveyed at least on a triennial basis with a site survey team
of at least a hospital administrator, a physician, and a nurse. The survey lasts for approximately
three days. An accreditation survey begins with an opening conference at the organization's
primary headquarters location. The survey team meets with representatives from the
organization's administrative and clinical staff to determine an agenda for the survey. Also at
this time, members of the public are invited to participate in any discussions with survey team
members. Compliance is assessed through a variety of means: written documentation; on-site

observations by surveyors; and, verbal information obtained from staff. Each standard is scored
on a five point rating scale that reflects substantial, significant, partial, minimal, or
noncompliance. If an unsatisfactory compliance score of 3, 4, or 5 is recorded, it must be
accompanied by a surveyor's written documentation. Surveyors use formal scoring guidelines to
promote consistency and these evaluations are both quantitative and qualitative.

JCAHO and The Federal Government

The federal Medicare program was created in 1965 and since then the Medicare program has
accepted JCAHO accreditation was equivalent to compliance with Medicare certification
standards. Over the years, the accreditation system has evolved to respond to consumer concerns
as well as those from the medical and healthcare sectors. These changes, over the years, have
created a somewhat different system than the one established in 1965. However, and perhaps
most significant is that the federal government still continues to rely on JCAHO for
accreditation. In fact, in the early 1990's the Health Care Financing Administration (HCFA), the
body of HHS that administers Medicare, added JCAHO accreditation of home health
organizations to its already growing list of healthcare facilities accredited by JCAHO.

Despite some concerns from patient advocacy groups, the general sense is that the relationship
between JCAHO and HCFA has evolved into a productive and cost-effective one. And, in
addition, despite the fact that many of the original reasons for peer review in the Medicare
program (which were primarily political in nature) have all but disappeared, the federal
government (HCFA) has continued to favor self-regulation in the Medicare program. Why?

Scholars point to two major reasons why self-regulation has flourished: cost and flexibility. The
GAO reports that HCFA estimated that it would cost $59 million and require over 700 additional
full-time employees for it to assume responsibility for surveying all hospitals for Medicare
compliance. This would require increasing the size of HCFA by almost a third. HCFA would
have to hire, train, and maintain a staff of costly professionals, including physicians, nurses, and
attorneys to formulate and enforce program standards. To the extent that JCAHO can rely on the
expertise of its member groups for assistance in formulating and revising standards may avoid
some costs that the government would incur in operating a regulatory program. A second reason
may offer an additional explanation as to why accreditation has prevailed in the healthcare filed -
- flexibility. The JCAHO is better able than HCFA to adapt its standards to incorporate the
changing technology of the health care field.
11 The advantage that private standard-setting
bodies enjoy over public ones in the areas of flexibility and responsiveness has been noted in a
variety of areas including toxic substance regulation. According to Cheit:

Private standard setting is prospective and ongoing, while public efforts tend to be
corrective and singular. Private standard setters tend to intervene relatively early
in the life cycle of an issue, adjusting the subsequent standards over time, often
after a major disaster, and to adopt a "one-shot" standard that is not later revised.

According to Jost1 2 HCFA is not only subject to the Notice and Comment constraints of the
Administrative Procedure Act (APA), but is also subject to close scrutiny of the Office of
Management and Budget. As the Director of HCFA's Health Standards and Quality Bureau
acknowledged at a congressional hearing:

Private sector organizations don't need to issue proposed rules, final rules, et
cetera, to deal with everybody in the country that has a better idea. They can go
and pretty much set standards that are the state of the art. That is a big
encumbrance for the government. We will never match private sector standards
vis-à-vis the state of the art. That is why deeming in general terms is a fairly good

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The JCAHO model underscores some of the most promising aspects of accreditation including
technical expertise, flexibility, and cost savings to the federal government. Two additional
advantages, which may appear to be less prominent in the discussion of JCAHO, are: incentives
for compliance, and more generally, advantages to government reinvention in an era of political
and fiscal constraint.

Accreditation or industry self-regulation is often lauded for its ability to draw on the expertise of
people outside the regulatory agency. In countless examples, from the stock market to meat and
poultry inspections, lawyers, political scientists and economists have argued that the industry
self-regulation can be more effective because of the self-regulator's superior knowledge of the

Surely, one product of the expertise of those involved in industry accreditation is that they retain
the to modify their rules in response to technological change more readily than does the
government agency. In the cas4e of health care, it was quite clear that changes in medical
technology were more readily applied and adapted to JCAHO standard than if HCFA had to go
through a long and protracted rule making process. Equally important is that industry
accreditation can better determine when a rule or standard should be changed to result in greater
compliance. As Bardach and Kagan
13 point out, private decision makers will be sensitive to the
adverse consequences of overzealous regulation and are likely to resist literal interpretations of
the rules, to accept "substantial" compliance, and to fight for discretion when the standards are
too burdensome or inappropriate.

Accreditation by industry representatives also has the positive effect of creating incentives for
In this regard, standards created by experts, which are relevant and tailored to the
industry, are perceived to be reasonable and meritorious. The regulated entity, because of its
own participation, is more open to cooperation and compliance than if it perceives rigid and
inappropriate standard setting. Industry participation in rule making is more likely to be
perceived as consistent with the entity' goals.

Finally, there has been some thinking about the extent and degree to which accreditation can be
part of government reinvention and regulatory reform. Scholars who have written in the area of
bureaucracy and regulation have long argued that throughout U.S. history there have been
different regulatory eras. In earlier periods including the Progressive Era and the New Deal Era
it was efficient and effective to limit discretion in enforcement and to respond to particular

problems in a legalistic fashion -- specific standards, allegations of violations, and a trial-type
adjudication of the facts. In this environment, those who were regulated would have the benefit
of objective rules, limiting the discretion of the agency, and the benefit numerous citations issued
under the new law. By the late 1970's considerable thinking about the benefits of deregulation
filtered into many think tanks, universities, government and the popular media. Most recently
we can see this influence in the reinventing government, national performance review movement
spearheaded by Vice President Gore.

Here, the principles of "reinventing government" are fulfilled in accreditation. They emphasize
a focus on performance, a focus on standards of output, rather than characteristics of input, and
far greater discretion and less reliance on handbooks, guidebooks and written standards.
Recently, administrators of "social" regulation have begun experimenting with output standards,
specifying results to be reached and leaving the exact method of achieving them to the regulated
entities. Accreditation seems to be consistent with much of this thinking and is likely to be a
fundamental part of regulatory reform especially; it is argued, in a time of increased political
constraint on federal spending.

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The JCAHO has played an important role in promoting change in the health care industry.
However, no system is without some problems and need for improvement. Over the years,
patient advocates have argued that HCFA should step up its validation efforts and determine how
effective and accurate JCAHO recommendations are. An interview with an official in HCFA
indicated that the agency is attempting to make progress in this area. According to this official,
HCFA's validation efforts have been enhanced through a process of random surveying, but that
more money was needed to further increase these efforts.
14 In addition to HCFA's validation
visits, JCAHO has recently begun unannounced visits and reviews of 5% of the accredited
institutions annually.

Also of concern is the issue of conflict of interest in the case of JCAHO. Here, some groups
have expressed concern that JCAHO is too closely tied to the industry it accredits. In the case of
JCAHO, 21 of the 28 board members are appointed by groups such as the American Medical
Association and the American Hospital Association. A recently introduced Bill, H.R. 800, if
passed, would ensure that at least one third of the governing board consist of members of the
public. The bill would also require all Medicare accrediting organizations hold public meetings.

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In addition to health care, accreditation in education offers a number of important insights for
any future consideration of accreditation in public housing. However, for purposes of brevity
and because accreditation in education is structurally complex and is governed by regional
accrediting bodies, what follows is a summary of the key attributes of education accreditation.

The statutory basis for federal reliance on private accreditation of higher education was
developed principally in the GI Bill (Veterans' Readjustment Assistance Act of 1952). Student
aid was available only for courses offered by an institution "accredited and approved by a
nationally recognized accrediting agency or association" and the Commissioner of Education
was required to publish a list of these nationally accredited agencies. However, the system of
self-accreditation in education dates back to the early part of the twentieth century where there
was a perceived need to develop uniform standards for colleges and ten, later, in secondary

schools. From the outset began the six regional associations of colleges that today accredit
thousands of institutions. Later, two additional tracks of educational accreditation developed:
one for proprietary institutions and the other for specialized accreditation programs, schools or
colleges within an institution.

Under Title IV of the Higher Education Amendments of 1992 (Pub. L. No. 102-325), an
institution must satisfy the "Program Integrity Triad" to receive federal student assistance
monies. As the name suggests, there are three requirements: 1) satisfactory findings, by a state
post-secondary review entity, of eligibility for federal student assistance programs; 2) approval
of an accrediting agency or association; and 3) certification by the Secretary of Education of the
institution's financial responsibility and administrative capacity.

The Act provides that the Secretary of Education designate one state post-secondary review
entity in each state to coordinate and institution's eligibility. The second requirement for
participation is institutional approval by an accrediting agency. Here, the Secretary regularly
publishes a list of accrediting bodies that he determines to be a "reliable authority as to the
quality of education offered." To be determined as such, the accrediting agency must satisfy
certain statutory criteria of its own, and employ certain standards in its accrediting process.
These standards include factors such as curricula; faculty; facilities and supplies. Finally,
assuming that an institution of higher education has received the requisite approvals from both a
state post-secondary review entity and an accrediting agency, the Secretary of Education must
still certify it to receive federal student financial assistance. Once the Secretary has made this
certification the institution is eligible for participation in federal student financial assistance
programs for a maximum of five years subject to a program review schedule promulgated by the

In the Department of Education, as is the case with HHS and HCFA, the Secretary has ample
opportunity to intervene in the final determination. In education, the Secretary determines that
the institution possesses the requisite fiscal responsibility and administrative capacity to
participate in federal student financial assistance programs. In addition, the Office of Program
Enforcement conducts audits and can, if it determines noncompliance with Title IV, revoke
certification and institute a recovery action to recover funds. In HHS, as discussed earlier, the
Secretary retains ultimate authority for determining a hospital's eligibility for the program. The
Secretary and HCFA can conduct validation surveys that could ultimately lead to changes in an
institution's "deemed" status. In sum, accreditation does not render the government agency
impotent and unable to exercise the requisite control when needed. In both cases, there is
statutory language that spells out these oversight roles and much the same could be employed in
any accreditation scheme for public housing.

Also, what makes education so interesting and relevant to our discussion of public housing is the
fact that over the years the emphasis of accreditation has changed dramatically. The early
emphasis was on uniformity of standards, but the modern emphasis is on the assessment of the
institution's compliance with its own standards and progress towards its own goals. Thus,
private accreditation is today not a comparison to uniform standards, but rather a judgement, by
peers, that an educational institution has set its goals and ways to meet them.

Part of the tradition in education has been one of diversity and local control. In fact, when
Congress began the aid programs in the 1950's, it chose to rely on accrediting organizations
partly to avoid any such federal control and partly because accrediting organizations were
recognized as expert and reliable. Accreditation in education is perhaps distinctive, but it may be
especially appropriate for public housing. Accreditation is based on three basic precepts:

The federal government's role and major function regarding post-secondary education is to
establish national priorities and objectives for education spending and to provide funds. In order
to implement these goals and priorities, the federal government attaches a wide range of
conditions to the funds it makes available. How much influence it exerts will, of course, always
be a political issue. Is it too much, is it coercion, or is it too little? The balance will shift, but the
basic, fundamental structure remains -- peer review dominates the accreditation process.

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Now is the time to seriously conduct a study of accreditation and its applicability to public
housing. The current system for monitoring and evaluating PHAs is not adequate --it is not
adequate for HUD, it is not adequate for the industry, and it is not adequate for the residents.
The Secretary has acknowledged these problems, the GAO has demonstrated these problems,
and the Congress, as it considers public housing reform, is ready to act on them. We believe that
a careful and systematic study of accreditation can only benefit the public housing industry.
There is ample evidence to suggest that accreditation is a reasonable and thoughtful way to
approach improving public housing. This paper has begun to demonstrate that there are
successful examples of accreditation in both the healthcare field and in education, which can be
applied to public housing. In both cases, substantial amounts of federal funds are expended
through a system which makes use of peer review and evaluation. We have come to rely on
these self-regulating systems and have demonstrated, over the years, significant advantage that
accrue as a result. We have come to expect cost-savings, flexibility, and innovation form these
alternatives to government regulation.

We recommended, as we did last year, that a study commission be established to further examine
accreditation models in other industries to determine their applicability to public housing. The
composition of the commission should reflect meaningful participation and contribution from
professionals in public housing operations, property management, asset management, local
government, public housing residents, and public administration. The commission should be
charged with the responsibility to make recommendations to Congress on the development and
implementation of an accreditation system for public housing. These recommendations should

be made and considered prior to launching a full-blown accreditation board as proposed in H.R.

There is strong support for an industry driven study commission composed of representatives of
the following organizations:

In an effort to provide timely information, we recommend that the study commission report to
Congress within six months form the time the commission is fully appointed. If the study
recommends that an accreditation entity be established, it should also offer a timetable for
developing and implementing such a system for congressional action.

In making the recommendation that a study of public housing accreditation take place, we
acknowledge that there are many essential questions that need to be answered. At the very least
we need to address the following key questions:

  1. How can we avoid duplication between HUD and the accreditation entity?
  2. What are the defined roles and activities of HUD and the accreditation entity?
  3. Who should be appointed to the accreditation entity?
  4. Is peer review a credible opportunity for public housing?
  5. Who does the actual assessment including visiting sites, evaluating plans, etc... ?
  6. How much will accreditation cost?

Finally, as the study commences and future discussion of public housing accreditation is
considered, one additional key point needs to be made: Accreditation is designed to free HUD
from some aspects of regulatory oversight that it has been unable to fully and effectively carry
out. Accreditation is not meant to supplant HUD's regulatory functions, it is conceived as
supplementing functions that HUD, due to downsizing and related staff shortages in certain key
areas such as real estate management, has experienced. More to the point, it is our expectation
that even with an accreditation system, HUD will retain ultimate authority and responsibility.

We would anticipate that the Secretary would have the authority to seek a judicial receiver. The
tow models that we have presented, the health care system and JCAHO and the education system
and its accreditation process, both suggest a strong interplay between the federal government and
the accreditation entity. We anticipate much the same as we begin to study the possibility of
self-regulation for public housing.

Committee Report No. 98-142 {To accompany S. 1338}, the Housing and Community Development Act of 1983,
The Final Report of the National Commission on Severely Distressed Public Housing, A Report to Congress and
the Secretary of Housing and Urban Development, August 1992, p.113.
Examples of industry driven innovation include: a push for an assessment, monitoring, and performance system;
revitalization of distressed public housing; mixed-finance development; and, creation of an industry-operated public
housing insurance company.
"HUD Should Improve the Usefulness and Accuracy of Its Management Assessment Program," GAO, Report to
Chairman, Subcommittee on Housing and Community Opportunity, Committee on Banking and Financial Services,
House of Representatives, January 1997.
Secretary Andrew Cuomo's Statement Before the Senate Committee on Banking, Housing and Urban Affairs.
April 9, 1997.
Eleanor D. Kinney, "Private Accreditation as a Substitute for Direct Government Regulation Public Health
Insurance Programs: When Is It Appropriate? In Clark Havighurst, Private Accreditation in the Regulatory State,
Law and Contempor