HUD-4119 Appendix Challenging Population Projections Data

OMB Control No: 2577-0218

Expiration Date: XX/XX/XXXX

HUD 4119 Appendix A: Challenging Census Population Projections Data: Guidelines for the Indian Housing Block Grant Formula

Public Reporting Burden Statement: This collection of information is estimated to average 10 hours per response, including the time for reviewing instructions, searching existing data sources, gathering, and maintaining the data needed, and completing and reviewing the collection of the requested information. Comments regarding the accuracy of this burden estimate and any suggestions for reducing this burden can be sent to: U.S. Department of Housing and Urban Development, Office of the Chief Data Officer, R, 451 7th St SW, Room 8210, Washington, DC 20410-5000. Do not send completed forms to this address. This agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection displays a valid OMB control number. This agency is authorized to collect this information under Section 102 of the Department of Housing and Urban Development Reform Act of 1989. The information you provide will enable HUD to carry out its responsibilities under this Act and ensure greater accountability and integrity in the provision of certain types of assistance administered by HUD. This information is required to obtain the benefit sought in the grant program. Failure to provide any required information may delay the processing of your application and may result in sanctions and penalties including the administrative and civil money penalties specified under 24 CFR §4.38. This information will not be held confidential and may be made available to the public in accordance with the Freedom of Information Act (5 U.S.C. §552). The information contained on the form is not retrieved by a personal identifier, therefore it does not meet the threshold for a Privacy Act Statement.

This document, in question-and-answer format, outlines the steps HUD requires for a Tribe to challenge the Bureau of the Census Population Projections data used in calculating the Needs component of the Indian Housing Block Grant (IHBG) formula to project Decennial Census person counts or Tribal survey data to the present.

Q1. How is the Needs component of the IHBG formula affected by the Census Bureau Population Projections?

A1. In accordance with 24 CFR 1000.330(b), the data for one Needs variable, the American Indian and Alaska Native (AIAN) person count, are adjusted annually. AIAN person counts used in the Formula are derived from the most recent Decennial Census unless a HUD has approved a Census challenge to that data submitted by the Tribe. These data are adjusted to reflect demographic shifts which have occurred at the county level since the Decennial Census using population projections prepared by the Census Bureau annually. If the person counts are based on data submitted by the Tribe, they will be adjusted from the year of first use in the Formula to the most recent year reflected in the Census Population Projections.

Q2. Can Tribes/Tribally Designated Housing Entities (TDHE) challenge Population Projections?

A2. Yes. In accordance with 24 CFR 1000.330(c) and 24 CFR 1000.336, a Tribe/TDHE may challenge Census Population projections data. A challenge may be submitted to the IHBG Formula Customer Service Center if Tribes/TDHEs believe the adjustment to their Census data is incorrect. HUD will approve the challenge only if HUD has incorrectly used the Census Population Projections to adjust the Needs data for the Tribe's Formula Area. If the problem is with the underlying Census Data, then a challenge must be directed to the Census Bureau and conform to regulations governing them, found at 15 CFR Part 90. All challenges must utilize the estimation methodology used by the Census for a particular level of geography. Challenges are accepted by the Census Bureau only when evidence is provided regarding errors in data or calculation.

Q3. What is the procedure for challenging Census Population Projections?

A3. To challenge HUD's application of Census Population Projections data to the Tribe's Formula Area, submit a letter following the same procedures for correcting other data on the Formula Response Form. To challenge the underlying Census Populations Projections data, follow Census Bureau procedures, which may be found at https://www.census.gov/programs- surveys/popest/about/challenge-program.html. Inform the IHBG Formula Customer Service Center of challenges you submit to Census.

All data and approval documentation should be sent to:

IHBG Formula Customer Service Center

101 Ridgely Ave, Suite 10

Annapolis, MD 21401

Toll Free: 800-410-8808

Fax: 202-393-6411

E-mail: IHBGformula@firstpic.org

HUD 4119-A