HUD-4119 Challenging Population Projections Data

Appendix A: Challenging Population Projections Data

Challenging Census Population Projections Data: Guidelines for the
Indian Housing Block Grant Formula
This document, in question and answer format, outlines the steps HUD requires for a
tribe to challenge the Bureau of the Census Population Projections data used in calculating the
Needs component of the Indian Housing Block Grant (IHBG) formula to project 2010 Census
person counts or tribal survey data to the present.
Q1: How is the Needs component of the IHBG formula affected by the Census Bureau
Population Projections?
A1: In accordance with 24 CFR 1000.330(b), the data for one Needs variable, the American
Indian and Alaska Native (AIAN) person count, are adjusted annually. AIAN person counts
used in the Formula are derived from the most recent Decennial Census unless a HUD has
approved a Census challenge to that data submitted by the Tribe. These data are adjusted to
reflect demographic shifts which have occurred at the county level since the Decennial Census
using population projections prepared by the Census Bureau annually. If the person counts are
based on data submitted by the Tribe, they will be adjusted from the year of first use in the
Formula to the most recent year reflected in the Census Population Projections.
Q2: Can tribes or tribally designated housing entities (TDHE) challenge Population
Projections?
A2: Yes. In accordance with §1000.330(c) and §1000.336, a tribe/TDHE may challenge
Census Population projections data. A challenge may be submitted to the IHBG Formula
Customer Service Center if Tribes/TDHEs believe the adjustment to their Census data is
incorrect. HUD will approve the challenge only if HUD has incorrectly used the Census
Population Projections to adjust the needs data for the Tribe's Formula Area. If the problem is
with the underlying Census Data, then a challenge must be directed to the Census Bureau and
conform to regulations governing them, found at 15 CFR Part 90. All challenges must utilize
the estimation methodology used by the Census for a particular level of geography. Challenges
are accepted by the Census Bureau only when evidence is provided regarding errors in data or
calculation.
Q3:

What is the procedure for challenging Census Population Projections?

A3: To challenge HUD's application of Census Population Projections data to the Tribe's
Formula Area, submit a letter following the same procedures for correcting other data on the
Formula Response Form. To challenge the underlying Census Populations Projections data,
follow Census Bureau procedures, which may be found at https://www.census.gov/programssurveys/popest/about/challenge-program.html. Inform the IHBG Formula Customer Service
Center of challenges you submit to Census.

Appendix A: Challenging Population Projections Data

All data and approval documentation should be sent to:
IHBG Formula Customer Service Center
1875 Connecticut Ave., NW, 10th Floor
Washington, D.C. 20009
Toll Free: 800-410-8808
Fax: 202-393-6411
E-mail: IHBGformula@firstpic.org