Housing Counseling Process Evaluation and Design of ... - HUD User

national counseling standards should be the responsibility of HUD or a third party outside the
intermediary network to avoid overburdening intermediaries and SHFAs. Others raised concerns
about additional reporting requirements associated with meeting the standards discouraging small
agencies from participating in the counseling program.
For intermediaries and SHFAs that do not support the creation of national standards for housing
counseling, one of the major reasons is the potential to reduce access to housing counseling in some
areas if small or rural agencies are unable to meet the added standards or reporting burdens. Two
organizations that fund counseling in rural areas put it this way:
“It is a dilemma. No one would disagree that we should be shooting for the highest standard
conceivable given the constraints that we operate under, the largest of which is a funding
constraint. If higher standards would result in some people not having access to counseling,
that would not be a good outcome. Any counseling is probably better than no counseling.
We don’t want to see viable counseling undercut; at the same time, we need some minimal
level of competence, and this is what HUD should be working on.”
“National counseling standards impose limitations and costs on rural organizations, perhaps
more so than larger, sophisticated, or urban organizations. A current issue with standards and
certification is that rural organizations find it very difficult to travel and attend required
training. Training is offered in urban areas and sometimes only once a year. The
administrative costs of standards may also burden small, rural organizations. HUD should
also approve state and local-level standards and the associated certifications.”
Intermediaries and SHFAs were also asked about HUD’s role in setting and enforcing national
standards for the counseling industry. Overall, about 80 percent of the organizations interviewed said
HUD should have some role in setting and enforcing the standards, but the extent of that role varied.
Most said they thought HUD should endorse the standards once developed, make sure that they are
included in the HUD handbook, and provide training funds for agencies to meet the standards.
However, there was little consensus about how the standards should be enforced and what HUD’s
role should be. Most acknowledged that HUD is a major player in the industry and should therefore
play a role, but the organizations were equally split between those who said HUD should lead the
enforcement of standards and those who thought it should be up to another entity or that
intermediaries, SHFAs, and local agencies should be self-policing.
There was also no consensus about whether the existing NCHEC standards were sufficient for
homeownership-related counseling or whether NCHEC should take the lead in developing additional
standards. Not everyone interviewed was familiar with the standards, and several raised concerns
about NCHEC’s standards being too closely tied to training offered by NeighborWorks® America.
Some suggested that although the standards should come from the industry, the certifying body
should be independent to avoid conflicts of interest.
Agency Views on National Standards
The counseling agency survey explored the question of which types of industry standards might be
needed for different types of services. Specifically, for each education or counseling service funded
148
Chapter 9. Policy Considerations