Challenging Census Data Used in the Indian Housing Block Grant (IHBG)


View our interactive map of the 2017 IHBG need allocation.

Village Earth has extensive experience assisting Native American tribes and TDHE’s to challenge the Census numbers used to allocate Federal housing funding to Native American Tribes through the Indian Housing Block Grant or IHBG including the following Reservations: Pine Ridge, Rosebud, Cheyenne River, Turtle Mountain, Lower Brule, Fort Berthold, and Red Lake.

About the IHBG Formula
In 2017, the IHBG will total $693,290,879 and will be distributed to 587 Tribes or Tribally Designated Entities, or TDHE’s. The amount each tribe receives is based on a national operating and modernization subsidy for the number of low rent, homeownership and section 8 houses that each tribe assists. The IHBG formula also includes additional funding based on the seven “need-based” variables weighted in the following manner:

  • 11% Number of American Indian Alaskan Native (AIAN) persons
  • 13% Number of AIAN households with less than 30% of area median income
  • 7% Number of AIAN households with income between 30% and 50% of area median income
  • 7% Number of AIAN households with incomes between 50% and 80% of formula median income
  • 25% Number of AIAN household overcrowded and/or without complete kitchen or plumbing
  • 22% Number of AIAN household with housing costs burden greater than 50% of area annual income
  • 15% Number of AIAN households with a formula annual income up to 80% of formula median income less the number of assisted households (Current Assisted Stock CAS).

Until 2018, data for the needs variables came from the 2000 Federal Census but adjusted each year to account for population growth. In 2017, the need portion of the IHBG will account for $414,238,801 or 60% of the total IHBG. In 2018, the population data for the formula will be drawn from the 2010 census adjusted each year for population growth while data for the other variables will be drawn from the American Community Survey 5-year estimates.

Challenging the Census Data Used to determine the IHBG
According to 24 CFR 1000.336, Tribes and TDHE’s may challenge or appeal the data used to determine its IHBG Funding. The most common way to challenge the needs data is to conduct your own survey. Tribes with fewer than 575  households are require to collect surveys from every household with a 70% response rate. Tribes with more than 575 households are allowed to do a random sample, collecting data from at least 400 households with a 70% response rate. Regardless of whether you have 575, 1000, 5000, or 10,000 households, you still only need to collect data from 400 households.

The first step in conducting a census challenge is to compile a list of all housing units within your formula area, this might include a directory with phone numbers and/or addresses, Tribal enrollment list, rural 911 map, or something equivalent. Village Earth can assist in the creation of a database if you do not already have one. We can also help you assess the potential for increasing your allocation before engaging in full-scale challenge. 

Challenge Deadline

Results of your census challenge must be submitted before March 31st, 2017 to be considered and to impact your funding allocation for 2018.