Access NAHRO's HUD Salary Search Tool by clicking here.
In August 2011, HUD published Notice PIH 2011-48 instituting a requirement that all PHAs report salary information for their top five compensated employees. No similar requirement exists for any other recipient of HUD funding. The Department declared its intention to collect this information through notices published in the Federal Register on April 26 and July 11, 2011. NAHRO submitted detailed comments responding to each of these notices.
In addition to responding to these notices, NAHRO also submitted a request under the Freedom of Information Act (FOIA) for “the names, titles, and compensation levels of all HUD employees, including political appointees, whose compensation levels, exclusive of health, retirement and other fringe benefits, exceed $100,000 per year, together with the annual value of health, retirement and other fringe benefits provided to such persons.” HUD responded to NAHRO’s FOIA request by providing a listing of all employees with base salaries of $100,000 or more, along with their titles and locations.
The information provided by HUD includes only base rates of pay; HUD declined to provide information on the value of individual benefits packages, claiming that “each employee chooses their benefits package on an individual basis” and that to “construct a profile for each employee would require a record to be created for each person listed” and “cause an undue hardship on the Department” as defined under previous FOIA-related court rulings. (NAHRO notes that HUD requires PHAs to submit compensation information beyond base salaries. For their five highest compensated employees, PHAs must also report additional forms of compensation such as amounts paid to an employee’s health insurance provider, retirement plan, the Social Security Trust fund, and Medicare, and even amounts paid by the employee, including health care premiums and IRA contributions.)
All data received in response to NAHRO’s FOIA request may be accessed through NAHRO’s HUD Salary Search Tool. The data is searchable by last name*, state, HUD Region, HUD office, or any combination thereof. Data provided is current as of June 2011. NAHRO intends to request this information and update the database on an annual basis.
*Although users may search by an employee’s last name, for privacy purposes last names are not visible in the displayed search results.
Why is NAHRO providing this information?
To be clear, NAHRO agrees that the administration has a responsibility, as expressed by Assistant Secretary Sandra Henriquez during testimony before Congress, “to ensure good stewardship of taxpayer dollars and promote transparency in government.” However, in addition to expressing opposition to an overly burdensome information collection, NAHRO consistently voiced its concern that the Department would not do enough to place the reported data in its proper context. We would contend that HUD has created a false pretext of comparability between PHAs of different sizes and geographies. Without providing information regarding the job markets in which PHAs are located, the responsibilities included in each position, the seniority and experience level of the employee, the total budgets each PHA (or its Affiliate/Instrumentality) manages (including Public Housing, Voucher programs, Project-Based Section 8 Multi-family Housing Assistance, Low-Income Housing Tax Credits, Section 202, Shelter-Plus Care, and other federal-, state- and local-funded housing, homelessness, and community development programs), and the extent to which PHA salaries are supported by non-federal funding sources, HUD’s presentation of the reported data is ripe for exploitation and misinterpretation, thus running entirely counter to HUD’s justification of transparency and accountability.
A true evaluation of public housing compensation would measure pay packages against the salaries and benefits received by other professionals (in both the private and public sectors) engaged in the development and provision of affordable housing. HUD is imposing no similar reporting and transparency requirement on the private owners of federally subsidized housing, or on private nonprofit and for-profit developers of affordable housing who benefit from HUD subsidies. Indeed, the Department is subjecting public housing employees to an unreasonable degree of public scrutiny - and, as of June 2012, proposing to cap public housing employees' salaries - even as highly compensated HUD officials and career employees, all of whom receive 100 percent of their salaries through taxpayer dollars, have not been asked to sacrifice similarly any measure of their own privacy in the name of transparency and accountability.
NAHRO makes no judgment regarding the appropriateness of the salaries paid to HUD employees. Like public housing employees, most HUD employees are hard-working public servants who share our interest in expanding and preserving the supply of affordable housing, and building stronger communities through the effective administration of federal community development programs. NAHRO seeks simply to provide additional context for those who are interested in conducting a fair and impartial assessment of the compensation information reported by PHAs.
For more information and to review NAHRO’s previous reporting, see:
Nov 15, 2011: HUD's Transparency Double Standard
Oct. 20, 2011: NAHRO Obtains Top HUD Salaries