The authority stack

The exact structure varies by program, but a typical pathway includes these layers:

  1. Federal authorization and funding
    Laws, regulations, appropriations, grants, and agency guidance establish the program.
  2. Local grantee administration
    A government grantee plans, awards, manages, and reports on funds.
  3. Project sponsors
    Organizations operate funded housing or service activities.
  4. Contractors or subcontractors
    Additional entities may perform defined parts of the work.
  5. Participant-facing staff
    Staff conduct intake, planning, referrals, housing activity, and follow-up.
  6. Monitoring and oversight
    Funders and administrators review performance, records, and corrective action.
  7. Participant records
    Files document eligibility, decisions, services, notices, and outcomes.

Shared responsibility should remain traceable

Several entities may lawfully share administrative work. The useful question is not whether one organization performs every task, but whether responsibilities are assigned, communicated, documented, monitored, and connected to outcomes.

Traceability test

Can a reviewer follow a decision or service from its governing authority to the responsible organization, the participant-facing action, and the resulting record?

Records connect delivery and oversight

Grant agreements, contracts, policies, participant files, financial records, performance reports, monitoring workpapers, and corrective-action records serve different purposes. Together, they can show what was authorized, who was responsible, what occurred, and what happened next.

Sources and Authorities

Scope note

These educational models describe common administrative principles and draw primarily from HUD HOPWA authorities and guidance. Program-specific requirements vary, and cited HOPWA authorities should not be treated as governing other housing programs unless independently applicable.

Last reviewed: July 2026