Final - STRD Supporting Statement Part B

Supporting Statement for Paperwork Reduction Act Submissions

Stepped and Tiered Rent Demonstration Evaluation

OMB Control # 2528-xxxx

B. Collections of Information Employing Statistical Methods

1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

Evaluation Overview

Rent reform, a long-standing public policy goal for public housing and Housing Choice Vouchers and central to the Moving to Work (MTW) Demonstration, has multiple objectives: policy simplification; reduction in the public housing agency (PHA) administrative burden and costs; stronger financial incentives for tenants to work and make progress toward self-sufficiency; protecting families from hardship; and cost-effectiveness. As part of the U.S. Department of Housing and Urban Development’s (HUD) MTW expansion effort, one cohort of 10 newly selected MTW housing agencies is implementing alternative rent policies designed to achieve these objectives as part of the Stepped and Tiered Rent Demonstration.

Each PHA in this demonstration is implementing one alternative rent policy: four are implementing the HUD-defined tiered rent model, five are implementing the HUD-defined stepped rent model, and one is implementing their own proposed tiered rent model that conforms with HUD’s criteria for the demonstration. Tiered rent models are tied to income, and families move from one rent tier to the next based on their income bands at triennial recertifications. Stepped rents, on the other hand, are decoupled from income and increase annually, unless eligible hardship circumstances are present. Triennial recertifications are conducted under the stepped rent model only to determine families’ continued eligibility for their HUD housing subsidy.

MDRC worked with HUD and the selected PHAs to design and implement the alternative rent policies and set the groundwork for a full-scale evaluation of the effects of the alternative rent polices. Phase I, the work funded so far, covers the period from 2018 to 2025. Study enrollment will last one year at each PHA began at the first PHAs in January 2023.

The Stepped and Tiered Rent Demonstration is also subject to a rigorous evaluation, using a randomized control trial and including implementation, impact, and cost study components. Approximately 29,000 households will be randomly allocated to two study groups: the alternative rent policy group, which will be subject to the new rent policy, and the control group, which will be subject to the existing rent rules. The demonstration focuses on working-age, non-disabled voucher holders and public housing residents, as these groups are defined in HUD regulations. Eligible households include both current public housing residents and voucher recipients as well as new households that enter the subsidy programs during the enrollment period. All eligible households are being randomly assigned and asked to provide informed consent to participate in the evaluation. Only households who consent to participate are considered study participants.

The evaluation will rely on multiple data sources described in previous OMB submissions and which are unchanged. Using these data, primarily administrative records, interviews and observational data, the evaluation is designed to produce a careful assessment of the implementation, impacts, and cost of the new rent models. Exhibit B.1 identifies the core data sources, some of which will be obtained and analyzed during the current Phase of this study (Phase I).

Exhibit B.1: Data Sources for the STRD Evaluation

DATA TYPE	DATA SOURCE
Baseline survey	MDRC Baseline Information Form, completed at study enrollment
	PHA and HUD PIC 50058
Housing Authority Data	PHA and HUD PIC 50058
Employment and Earnings from NDNH	Office of Child Support Enforcement
TANF and SNAP	State agencies
Homeless Management Information Systems (HMIS)	Local Continuum of Care
Qualitative data	Observations and PHA staff interviews

Exhibit B.2 shows the number of nonelderly, nondisabled households in PHA, as reported by the PHA in their applications. This total count of approximately 29,000 nonelderly, non-disabled households in these 10 PHAs translates into approximately 24,000 households being eligible for the demonstration, after accounting for the 18 to 56 years old age range (instead of the 18 to 61 years old age range reported by PHAs in their applications). The estimated sample size will be finalized during the implementation planning phase.

Exhibit B.2: Projected Sample Sizes by Site

State	PHA Name	Eligible Households
Tiered rent
OH	Akron Metropolitan Housing Authority	4,706
WA	Everett Housing Authority	1,340
WV	Charleston-Kanawha Housing Authority	1,947
OR	Housing Authority of Washington County	1,149
TX	Houston Housing Authority	11,491
Tiered Rent Total		20,633
Stepped rent
NC	Housing Authority of the City of Asheville	1,304
IN	Fort Wayne Housing Authority	2,230
CA	Housing Authority of the County of Kern	2,404
VA	Portsmouth Redevelopment and Housing Authority	1,366
UT	Housing Connect (Housing Authority of the County of Salt Lake)	1,131
Stepped Rent Total		8,435

As described in Supporting Statement Part A, a second round of PHA staff interviews is planned in the second half of 2024to continue data collection that will enable an analysis of the ongoing implementation of the alternative rent policies. The research team will aim to interview PHA leaders and housing specialists who are regularly involved in activities necessary for implementation of the alternative rent policies.

The interviews will cover a range of topics that get at the PHAs’ implementation experiences, including: their perspectives on continued implementation of alternative rent policy processes (such as recertifications, hardship rents), perceptions of the alternative rent policies by households subject to those policies, , reflections on the PHA operational contexts relevant to alternative rent policy implementation, and overall summary assessments of implementation successes and challenges.

Each PHA in the evaluation has been assigned a dedicated liaison from the MDRC team for the duration of the evaluation. The MDRC liaisons serve as the primary points of contact between the PHAs and the evaluation team and will be responsible for helping MDRC coordinate data collection efforts at the sites.

2. Describe the procedures for the collection of information including:

• Statistical methodology for stratification and sample selection,

• Estimation procedure,

• Degree of accuracy needed for the purpose described in the justification,

• Unusual problems requiring specialized sampling procedures, and

• Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

For the PHA staff interviews, MDRC will work with each PHA liaison to identify respondents. Where we identify more staff than we can interview perform a particular role, we will give priority to those with the most experience in administering the new rules, or those whom from our technical assistance work with the sites we believe would have especially important perspectives to offer. This approach will allow us to gather the data needed to answer the research questions.

We will not seek to draw statistical inferences from the staff interview data.

Impact Estimation Approach

The estimation strategy as described in previous submissions is unchanged. This demonstration uses an experimental design that randomly assigns households within each participating PHA to either the alternative rent policy or to a control group that will continue to be subject to the traditional percent-of-income rent policy. The power of the experimental research design will come from the fact that, with an adequate sample size, random assignment ensures that the intervention and control groups will be similar in terms of the distribution of observed and unobserved baseline and pre-baseline characteristics. Thus, post-baseline differences between the two groups can be interpreted as effects of the intervention.

The basic estimation strategy used here is analogous to the methodology that MDRC and other social science researchers have used in social experiments over the last few decades to generate credible results. The analysis will compare average outcomes for the intervention and control groups, and it will use regression adjustments to increase the precision of the statistical estimates that are performed. In making these adjustments, an outcome, such as “total earnings” or “total HAP” is regressed on an indicator for intervention group status and a range of other background characteristics. The following basic impact model would be used:

Y_i = α + βP_i + δX_i + ε_i

where: Y_i = the outcome measure for sample member i; P_i = one for program (or intervention) group members and zero for control group members; X_i = a set of background characteristics for sample member i; ε_i = a random error term for sample member i; β= the estimate of the impact of the program on the average value of the outcome; α=the intercept of the regression; and δ = the set of regression coefficients for the background characteristics.

A linear regression framework will be used for both continuous and dichotomous variables. For dichotomous outcomes – such as whether the person was ever employed during the follow-up period, the effects will also be estimated using a logistic regression. This sensitivity test will be especially important for outcomes that are close to 100 percent or 0 percent over the full sample. For example, whether a sample household is still receiving any housing subsidies is an outcome that is close to 100 percent for the sample because the percentage of households who lose their subsidies or leave the subsidy program each year is very small. If appropriate, Poisson or Negative Binomial regressions may be used for outcomes that take on only a few values (e.g., quarters of employment); and quantile regressions may be used to examine the distribution of impacts for continuous outcomes.

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

Based on our experience, nonresponse has not been an issue for PHA staff interviews, even though staff participation in research interviews is always voluntary. On similar projects and in the first round of PHA staff interviews conducted in 2023, the MDRC team was successful in scheduling and conducting 63 interviews with individuals identified for staff interviews, including executive staff and directors, managers and supervisors, and frontline housing specialists.

For the Round 2 interviews, MDRC will give the PHAs sufficient advance notification before beginning these interviews and will request their assistance in scheduling interviews. In the 6-8 weeks leading up to data collection, MDRC will connect with PHA liaisons, interview schedules, and identify a pool of staff for these interviews. During this outreach phase, MDRC will determine if any potential interviewees prefer an interview in a language other than English, and if any potential interviewees require a reasonable accommodation. As noted above, if we identify more staff than we can interview perform a particular role, we will give priority to those with the most experience in administering the new rules, or those whom from our technical assistance work with the sites we believe would have especially important perspectives to offer. Once the list is finalized, MDRC will conduct the necessary outreach, provide selected staff with relevant background information on the goals of the interview, the duration of the interview, and how the interviews will be conducted (in-person, individual or group, phone or video conference). We will offer reasonable accommodations and language translation services as needed. Staff will be informed that no special preparation will be needed from them for this interview.

For staff unable to participate in a scheduled interview, because of an unforeseen situation or a scheduling conflict, MDRC will attempt to reschedule the interview.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of test may be submitted for approval separately or in combination with the main collection of information.

Staff interviews: The proposed qualitative data collection protocols (which are designed to serve as discussion guides) adapt and build on the protocols used in previous rounds of field research conducted with PHAs that have or are currently implementing alternative rent policies. In this sense, the research team has had a chance to test how the types of questions used in the staff interview protocols work in the field and does not anticipate requiring advance protocol testing activities. MDRC will prepare training materials and train experienced interviewers to conduct the process study interviews. This training will be conducted over a 2-week period leading up to the interviews with PHA staff.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

HUD has contracted with MDRC and its partner, and Fink Research. The PHA staff interview protocols draw on similar data collection tools used for other HUD-commissioned evaluations that MDRC is leading. The HUD Contracting Officer’s Representative (COR) reviewed the baseline information form and the interview protocols and had them reviewed by other subject matter experts at HUD. If there are any questions about this submission, please call either the HUD COR, Paul Joice (312-913-8597) or one of the MDRC Co-Principal Investigators, James Riccio (212-340-8822) or Project Director, Nina Castells (212-340-7605). MDRC consulted Charles Michalopoulous and Howard Bloom on the statistical aspect of the study design. In addition, the following team members contributed to the development of the data collection tools:

Nandita Verma

Co-Principal Investigator, 212-340-8849

Jonathan Bigelow

Implementation Research Lead, 212-340-8646

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