oversight

Dallas Jewish Coalition for the Homeless, Supportive Housing Grant, TX21B960501, Dallas, Texas

Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-01-18.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                      U.S. Department of Housing and Urban Development
                                                      Southwest District Office of Inspector General
                                                      819 Taylor Street, Room 13A09
                                                      Fort Worth, Texas 76102

                                                      (817) 978-9309 FAX (817) 978-9316
                                                       http://www.hud.gov/oig/oigindex.html




January 18, 2000                                      00-251-FW-1801

MEMORANDUM FOR:                Katie Worsham
                               Director
                               Office of Community Planning and Development, 6AD


FROM:                  D. Michael Beard
                       District Inspector General for Audit, 6AGA

SUBJECT:               Dallas Jewish Coalition for the Homeless
                       Supportive Housing Grant
                       TX21B960501
                       Dallas, Texas


As part of a nationwide review of HUD’s Continuum of Care Program, we audited the Supportive
Housing Grant awarded to the Dallas Jewish Coalition for the Homeless (the Coalition). Our
objectives were to determine whether the Coalition:

       •   Implemented the grant in accordance with its application;
       •   Expended funds for eligible activities under Federal regulations and applicable cost
           principles;
       •   Maintained evidence of measurable results; and
       •   Expended funds timely.

To accomplish our objectives, we interviewed HUD and Coalition officials; visited the project
site; reviewed the grant application, grant agreement and progress report; and analyzed financial
records and participant reports.

As a result of our audit, we determined that the Coalition’s activities were consistent with its
application and that it expended funds timely. However, the Coalition did not have sufficient
documentation to determine whether it met the purpose of the grant. Further, the Coalition
allocated $91,948 in ineligible expenses to the grant. We recommend that the Coalition develop
measurable criteria so that it can measure grant activities. In addition, the Coalition should
reimburse its grant for ineligible expenses totaling $91,948. Further, the Coalition should revise
its cost allocation practices and procedures to prevent the allocation of ineligible expenses to the
grant.
                                                                                                 2


We provided the Coalition with a draft memorandum and discussed the results on December 2,
1999. The Coalition provided written comments to the draft on December 8, 1999. The Coalition
agreed that they would revise its performance measures. Further, the Coalition said it would
recalculate amounts charged to the grant. Also, the Coalition would seek a waiver from HUD for
some of the ineligible costs.

Within 60 days please give us, for each recommendation made in this memorandum report, a status
report on: (1) corrective action taken; (2) proposed corrective action and date to be completed; or
(3) why action is considered unnecessary. Also, please furnish us copies of any correspondence
or directive issued because of this review.
                                                                                                    3


Background

Title IV of the Stewart B. McKinney Homeless Assistance Act authorized the Supportive Housing
Program. The Program is designed to promote the development of supportive housing and
services. The Program encourages the use of innovative approaches to assist homeless persons
and provides supportive housing to enable them to live as independently as possible. Eligible
activities include:

           •   transitional housing;
           •   permanent housing for homeless persons with disabilities;
           •   new or increased supportive services for homeless people not living in supportive
               housing; and
           •   other types of innovative supportive housing for homeless persons.

The Coalition is a nonprofit organization established in 1986. The Coalition created the Vogel
Alcove Child Care Center for the Homeless (the Center) in 1989 to serve children of homeless
families residing in shelters and transitional housing. In April 1997, HUD awarded the Coalition
$555,660 in Supportive Housing Program funds for the Center to provide “new, expanded high
quality child care and social/psychological services to homeless families with children under the
age of six…” The Coalition signed the grant agreement in June 1997. The grant agreement
incorporated the Coalition’s application and lasts 3 years.

Grant Accomplishments Cannot Be Measured

Performance Measures

The Coalition listed the following performance measures in its application for funding:

           •   Provide an additional 801 homeless children with comprehensive child care and social
               service;
           •   Provide therapy to homeless children with developmental delays (40% of these
               children would show improvement within 3 months);
           •   Place 70% of its clients in stable child care services; and
           •   Provide 100% of all employed parents with get well services.

The Coalition’s application stated it would provide child care services to an additional 80
homeless children annually. To accomplish this, the Coalition would provide an additional 10
spaces per quarter at the Center. These children would live at Promise House, a transitional
housing provider for teenage mothers. The Coalition would also provide child care vouchers for
40 children (10 per quarter) living at affiliated homeless service agencies.

To meet its remaining performance measures, the Coalition agreed to provide comprehensive case
management and other supportive social services to each family. The Coalition also agreed to
provide a get well room for mildly ill children so that their parents would not have to miss work.

1
    Free child care and social services for 3 months per child.
                                                                                                                 4


Further, the Center’s staff were to assist families in obtaining subsidized child care by using local
Resource and Referral services.

Performance Cannot Be Measured

The Coalition did not keep sufficient records to reliably determine whether it served 80 additional
children between October 1, 1997, and September 30, 1998, and again between October 1, 1998,
and September 30, 1999. Therefore, we could not determine whether the Coalition provided the
level of services it proposed in its application. Although the Coalition exceeded its goal for
providing child care services off-site, the number of children served on-site has actually
decreased. As a result, the overall increase in the number of new children served is less than the
80 proposed. On the other hand, the cumulative number of children served in each year increased.

    Fiscal Year          Total New Children                    Total Children Served    Total Children Servedc
                          Served On-site a                     Off-site by Child Care
                                                                     Vouchersa
1996 - 1997                          341                                  0b                    1390
1997 - 1998                          356                                 69                     1657
1998 - 1999                          235                                 58                     1681
a
  Each child is counted only once.
b
  No children served off-site prior to grant award.
C
  Count is by month. Thus, each child is counted more than once.


Progress Reports Inaccurate and Incomplete

In its progress report for October 1997 through September 19982, the Coalition stated that it
provided child care services to an additional 80 children. However, as shown above, the
Coalition did not document this level of performance. The Coalition did not address its remaining
performance measures in its progress report. Coalition officials acknowledged that they did not
have any records to support the skill improvement of homeless children with developmental
delays.

The Coalition discontinued using the get well room because parents were not bringing sick
children to the center and the room was generally empty. However, if parents do drop off sick
children, then the Coalition could set the room aside quickly to serve those children.

Ineligible Participants Included in Cost Allocations

The Coalition charged the grant $23,764 for the cost of serving ineligible participants. Under the
grant, the Coalition could only charge the grant for off-site child care vouchers and on-site child
care for teen mothers residing at Promise House. However, the former acting Executive Director
believed that the Coalition was not receiving its grant funds quickly enough. In September 1998,
she insisted on an adjustment to their books that resulted in the grant being charged for the cost of
providing child care for all teen mothers. The Coalition continued to erroneously charge these
costs until January 1999 when the current Executive Director stopped the practice. The Executive

2
    The progress report for FY 1999 is not due until December 1999.
                                                                                                     5


Director determined that the Coalition could expend all of the grant funds by September 30, 1999,
a full year before the grant expired. The Coalition adjusted the charges for October through
December 1998, but did not go back and adjust the charges made from October 1997 through
September 1998. The Coalition should refund these charges.

Ineligible Salary Costs Charged to Grant

The Coalition allocated a disproportionate amount of salary costs to the grant, resulting in
overcharges of $64,084. The Coalition allocated 100 percent of the cost of two Early Childhood
Instructors and 50 percent of the cost of a case manager to the grant. A review of these employees’
time sheets showed that they spent significantly less time on grant activities. The Coalition should
reimburse its grant for the excess charges. Further, the Coalition should allocate salary expenses
commensurate with the number of children served or time spent on grant activities.

Costs Inappropriately Charged to Grant

The Coalition incorrectly charged $4,100 to its grant that it had already charged to its Emergency
Shelter Grant. These costs consisted of security services and maintenance costs incurred from
September 1998 to April 1999. The Coalition should reimburse its grant for these costs.

Recommendations:

We recommend that HUD:

1A. Require the Coalition to analyze their current operations and create measurable criteria to
    accurately measure grant activities. The revised measurement procedures should be
    discussed with and approved by HUD.

1B. Require the Coalition to reimburse its grant for $91,948.

1C. Require the Coalition to revise its cost allocation practices and procedures to prevent the
    future allocation of ineligible costs to the grant.
                                                                                            6


                                                                                    Attachment

                                       DISTRIBUTION

Secretary's Representative, 6AS
Comptroller, 6AF
Director, Accounting, 6AAF
Director, CPD, 6AD (4)
Saul N. Ramirez, Jr., Deputy Secretary, SD (Room 10100)
Kevin Simpson, Deputy General Counsel, CB (Room 10214)
Jon Cowan, Chief of Staff, S (Room 10000)
B. J. Thornberry, Special Asst. to the Deputy Secretary for Project Mgmt, SD (Room 10100)
Joseph Smith, Acting Assistant Secretary for Administration, A (Room 10110)
Hal C. DeCell III, A/S for Congressional and Intergovernmental Relations, J (Room 10120)
Ginny Terzano, Sr. Advisor to the Secretary, Office of Public Affairs, W (Room 10132)
Roger Chiang, Director of Scheduling and Advance (Room 10158)
Howard Glaser, Counselor to the Secretary, S (Room 10234)
Rhoda Glickman, Deputy Chief of Staff, S (Room 10226)
Todd Howe, Deputy Chief of Staff for Operations, S (Room 10226)
Jacquie Lawing, Deputy Chief of Staff for Programs & Policy, S (Room 10226)
Patricia Enright, Deputy A/S for Public Affairs, W (Room 10222)
Joseph Hacala, Special Asst for Inter-Faith Community Outreach (Room 10222)
Marcella Belt, Executive Officer for Admin Operations and Management (Room 10220)
Karen Hinton, Sr. Advisor to the Secretary for Pine Ridge Project (Room 10216)
Gail W. Laster, General Counsel, C (Room 10214)
Armando Falcon, Office of Federal Housing Enterprise Oversight (9th Floor Mail Room)
William Apgar, Assistant Secretary for Housing/FHA, H (Room 9100)
Susan Wachter, Office of Policy Development and Research (Room 8100)
Cardell Cooper, Assistant Secretary for CPD, D (Room 7100)
George S. Anderson, Office of Ginnie Mae, T (Room 6100)
Eva Plaza, Assistant Secretary for FHEO (Room 5100)
V. Stephen Carberry, Chief Procurement Officer, N (Room 5184)
Harold Lucas, Assistant Secretary for Public & Indian Housing, P (Room 4100)
Gloria R. Parker, Chief Information Officer, Q (Room 8206, L’Enfant Plaza)
Frank L. Davis, Director, Office of Dept Operations and Coordination, I (Room 2124)
Office of the Chief Financial Officer, F (Room 2202)
Edward Kraus,, Director, Enforcement Center, V, 200 Portals Bldg., Wash.D.C. 20024
Donald J. LaVoy, Acting Director, REAC, 800 Portals Bldg., X, Wash D.C. 20024
Ira Peppercorn, Director, Office of MF Assistance Restructuring, Y, 4000 Portals Bldg.,
       Wash. D.C. 20024
Mary Madden, Assistant Deputy Secretary for Field Policy & Mgmt, SDF (Room 7108) (2)
Deputy Chief Financial Officer for Operations, FF (Room 2202)
David Gibbons, Director, Office of Budget, FO (Room 3270)
FTW ALO, 6AF (2)
HQ ALO CPD, DOT (Room 7220) (2)
Dept. ALO, FM (Room 2206) (2)
                                                                                        7


Acquisitions Librarian, Library, AS (Room 8141)
Director, Hsg. & Comm. Devel. Issues, US GAO, 441 G St. NW, Room 2474
     Washington, DC 20548 Attn: Judy England-Joseph
Henry A. Waxman, Ranking Member, Comm. on Govt Reform,
     House of Rep., Washington, D.C. 20515
The Honorable Fred Thompson, Chairman, Comm. on Govt Affairs,
     U.S. Senate, Washington, D.C. 20510
The Honorable Joseph Lieberman, Ranking Member, Comm. on Govt Affairs,
     U.S. Senate, Washington, D.C. 20510
Cindy Fogleman, Subcomm. on Gen. Oversight & Invest., Room 212,
     O'Neill House Ofc. Bldg., Washington, D.C. 20515
The Honorable Dan Burton, Chairman, Committee on Govt Reform,
     House of Representatives, Washington, D.C. 20515
Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human
     Resources, B373 Rayburn House Ofc. Bldg., Washington, D.C. 20515 (2)
Steve Redburn, Chief, Housing Branch, Office of Management and Budget
     725 17th Street, NW, Room 9226, New Exec. Ofc. Bldg., Washington, D.C. 20503
Inspector General, G
Dallas Jewish Coalition for the Homeless, Dallas, Texas