ST. PETERSBURG HOUSING AUTHORITY
ST. PETERSBURG, FLORIDA
00-AT-202-1007
MAY 24, 2000
OFFICE OF AUDIT
SOUTHEAST/CARIBBEAN DISTRICT
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Issue Date
May 24, 2000
Audit Case Number
00-AT-202-1007
TO: Karen Cato-Turner, Director, Office of Public Housing, 4DPH
FROM: Nancy H. Cooper
District Inspector General for Audit-Southeast/Caribbean, 4AGA
SUBJECT: St. Petersburg Housing Authority
St. Petersburg, Florida
We have completed a review of the St. Petersburg Housing Authority (Authority). The purpose
of our review was to evaluate the efficiency and effectiveness of the Authority’s operations.
Specifically, we evaluated the Authority’s (1) procurement policies and practices, (2)
administration of its Section 8 Program, (3) controls over and uses of funds received from a
refinancing transaction, and (4) use of a master fund.
Our report includes four findings requiring follow-up action by your office. We will provide a
copy of this report to the Authority.
Within 60 days, please furnish a status report for each recommendation on: (1) the corrective
action taken; (2) the proposed corrective action and the date to be completed; or (3) why action
is considered unnecessary. Also, please furnish us copies of any correspondence or directives
issued related to the review.
Should you or your staff have questions, please contact James D. McKay, Assistant District
Inspector General for Audit, at (404) 331-3369, or Auditor Leigh Holm at (305) 536-5387.
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Management Memorandum
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Executive Summary
HUD received a complaint of irregularities in the Authority’s procurement practices and
requested us to perform an audit. Our overall objective was to determine whether the Authority
followed HUD’s and its own procurement policies and procedures in awarding and administering
contracts. During the audit, we expanded the audit scope to include administration of the Section
8 Program, controls over and uses of funds received from a refinancing transaction, and use of a
master fund.
The Authority’s procurement methods and contract administration needed improvement.
Management did not ensure that procurement was conducted in compliance with HUD and local
requirements. As a result, contract solicitations and awards did not meet related guidelines;
records lacked sufficient documentation of procurement histories; and, procurements did not
always promote fair and open competition. The Authority had no assurance that it received
services under non-competitive contracts at the most advantageous cost or from the most
qualified source. Furthermore, the Authority did not always follow its contract administration
procedures. Contract administrators did not always monitor contracts or approve payments based
on contractor performance.
We recommend your office assure the Authority establishes detailed written procedures and
assigns responsibility to: (1) ensure contract solicitations and awards meet HUD requirements as
well as its own procurement policy, (2) monitor contractor performance and payments, and (3)
implement a quality control system to monitor the contracting process. We also recommend your
office monitor the Authority’s procurement and contract administration process during your next
review to ensure the Authority’s procedures meet HUD requirements.
The Authority had not effectively administered its Section 8 Program for many years. It had not
established financial and management controls to monitor its budget, cash reserves, or leasing
rates. The problems appeared to stem, at least in part, from a lack of coordination between the
finance and program staff. Consequently, the Authority’s Section 8 bank accounts were in a
deficit position and its operating reserves were depleted. Furthermore, in fiscal year 1999, the
Authority lost an opportunity to house an additional 181 families and to earn additional income of
$93,346. Instead, the Authority accumulated excess funds of $857,585 which it had to return to
HUD. The Authority was already in debt to HUD for $173,683 for its 1997 and 1998 Moderate
Rehabilitation Program, and had overspent its 1999 Moderate Rehabilitation (MOD Rehab)
Program by $131,857 and its 2000 Section 8 Program by $188,849.
We recommend your office assure the Authority implements a new accounting system or
establishes additional controls to monitor the number of units leased to the amount of funds
available. We also recommend your office require a quarterly accounting for the amount of funds
drawn, the number of units leased, and the amount of funds on hand to assure the Authority does
not overdraw funds. Your office should also review the Authority’s allocation plan to assure the
administrative costs to the Section 8 and other programs are applicable and supported.
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Executive Summary
The Authority did not establish adequate controls over funds received from refinancing Rogall
Congregate. As a result, the Authority did not fully document how it spent $558,262 of $670,880
received from the refinancing transaction, and lacked controls to ensure an additional $400,000 to
$900,000 it will realize over the next several years will be spent as approved by its Board. Also,
the Authority did not provide HUD an accounting for the funds as required by its Memorandum
of Understanding (MOU) with HUD, and needed to reimburse HUD for funds due.
We recommend you review the Authority’s documentation supporting $363,230 transferred to
another project and the master fund. The documentation should show that the funds were used in
accordance with Board resolution. We also recommend your office establish a format for
reporting use of the ongoing savings and assure the Authority uses the ongoing savings in
accordance with HUD and Board requirements.
The Authority’s master fund did not meet HUD requirements, did not provide a clear accounting
for cash transactions, and allowed improper use of funds. We identified misuse of the fund in a
1992 audit. HUD instructed the Authority to discontinue its use and the Authority agreed to do
so. Despite such agreement, the fund was still in use and transfers of public housing funds had
continued to be made for another 7 years with virtually no accountability. At September 30,
1999, the Authority had misused at least $410,000 that we could identify.
We recommend your office assure the Authority reconciles the receivables and payables in the
interfund accounts, makes appropriate adjustments, and closes the master fund. We also
recommend you assure the Authority establishes a revolving fund accounting system to process
joint costs only. The system should have its own general ledger and be reconciled each month.
Furthermore, we recommend the Authority establishes additional controls to ensure the Authority
pays only specific program costs from funds provided for the specific program.
Exit Conference
We held an exit conference with the Authority on April 17, 2000. The Authority provided written
comments to our findings on May 2, 2000, which we considered in preparing our final report.
The Authority generally agreed with the finding issues, but took exception to some of our
statements regarding finding 1. The comments are summarized within each finding and included
in their entirety in Appendix C.
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Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 Procurement Needed Improvement 5
2 Management of Section 8 Program Needed Improvement 17
3 Inadequate Controls Over Rogall Funds 23
4 Inappropriate Transfers of Public Housing Funds From
Master Fund 29
Management Controls 35
Follow-Up On Prior Audits 37
Appendices
A Schedule of Ineligible and Unsupported Costs 39
B Summary of Procurement Deficiencies 41
C Authority Comments 43
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D Distribution 53
Abbreviations
ACC Annual Contributions Contract
CFR Code of Federal Regulations
HUD U.S. Department of Housing and Urban Development
MIS Management Information Systems Department
MOD REHAB Moderate Rehabilitation Program
MOU Memorandum of Understanding
PILOT Payment in Lieu of Taxes
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Introduction
Background
The St. Petersburg Housing Authority (Authority) was organized under the laws of the State of
Florida in 1937. Its purposes include development, acquisition, leasing, operation and
administration of Low Income Housing Programs according to the rules and regulations
prescribed by the U.S. Department of Housing and Urban Development (HUD). Its mission is to
provide decent, safe, sanitary, accessible, and affordable housing to the citizens of the City of St.
Petersburg and promote resident self-sufficiency.
The Authority is involved in various housing initiatives. It owns 4 conventional projects with a
total of 891 units. It manages one of the projects, a 336-unit development for disabled/elderly
residents. The remaining three are privately managed by H.J. Russell & Company. The Authority
also administers approximately 2,000 Section 8 certificates and vouchers. The Authority owns
and manages Rogall Congregate, a 150-unit Section 8 New Construction Project. The buildings
and equipment were acquired through the issuance of mortgage revenue refunding bonds in June
1994. The Authority prepares separate financial statements and keeps separate records for Rogall
Congregate. The Authority is also contract administrator for a 52-unit Section 8 project. The
Board of Commissioners formed the George F. Mehan Community Affordable Housing
Investment Corporation (Mehan). Through an Annual Contributions Contract (ACC) with HUD,
Mehan administers a Section 8 Housing Assistance Payment Contract with Greenview Manor,
LTD (Owner). The purpose is to provide housing for elderly and handicapped families.
A seven member Board of Commissioners oversees the Authority. The Chairman during our
audit period was J.W. Cate. The Board is responsible for setting policies on administrative
matters and reviewing and approving the Executive Director’s actions.
The Board hired Darrell J. Irions as Executive Director on November 13, 1995, and appointed
him as the Secretary of the Board and Contracting Officer for the Authority. The Executive
Director is responsible for overall planning, and management of the Authority, subject to approval
of the Board. He is the principal advisor to the Board on all matters of management, making
recommendations on improving methods and procedures, and analyzing records and reports by
staff to determine the effectiveness of the overall operations. As Contracting Officer, he is also
responsible to ensure that: 1) procurement is conducted in the most economical and efficient
manner; 2) sufficient procurement records are maintained; and 3) procedures are in compliance
with HUD and Authority procurement policies.
The Authority has experienced high staff turnover in the past several years. For example, it has
employed five Directors of Finance since 1995. Currently, the Internal Auditor is Acting Director
of Finance. A Contract Administrator was terminated in October 1998 after only 4 months. The
next Contract Administrator was hired in May 1999, and terminated in November 1999. The
Executive Director appointed various staff to act as contract administrators during the interim
periods.
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Introduction
The Authority maintained its records at 3250 5th Avenue North, St. Petersburg, Florida.
Funding
The Authority’s fiscal year is April 1 through March 31. Over the last 4 fiscal years, it received
an average of $1.5 million annually in HUD operating subsidy. It also received about $3.1 million
in Comprehensive Grant Program funds during fiscal years 1996 through 1998 and about
$533,000 in Drug Elimination Grant funds during fiscal years 1996 through 1997. HUD awarded
a $27 million HOPE VI grant in 1997 for revitalization of Jordan Park. After receiving the grant,
the Authority hired a firm to write its Revitalization Plan which HUD accepted. The Authority
then hired HOPE VI staff and began community involvement and relocation efforts. By August
1999, only about 118 of the 446 units at Jordan Park were available for occupancy due to
implementation of the grant. The Authority began full scale demolition in February 2000.
Audit objectives, scope and methodology
HUD requested us to perform an audit of this Authority after it received a complaint of
irregularities in procurement practices. Our overall objective was to determine whether the
Authority followed HUD’s and its own procurement policies and procedures in awarding and
administering its contracts. The Authority’s contract register listed 91 contracts valued at over $4
million. We reviewed a judgmental sample of 12 contracts having a contract value of $3.5 million
and contract payments totaling $1.7 million. We selected the contracts based on complaint issues
and large dollar values. During the audit, we expanded the audit scope to include administration
of the Section 8 Program, controls over and uses of funds received from a refinancing transaction,
and use of a master fund.
To accomplish our audit objectives, we:
• compared Authority procurement policies to HUD requirements and guidance;
• interviewed HUD and Authority officials, current and former staff, contractors and
unsuccessful bidders;
• examined specific procurement and financial records;
• reviewed the financial management over the Section 8 Program;
• reviewed the Authority’s use of its master fund to determine compliance with HUD
requirements;
• followed up on prior OIG and Independent Public Accountant’s audit reports and findings;
and,
• assessed related management controls.
Our review generally covered the period April 1, 1997, through July 31, 1999. We conducted
field work from April 1999 through October 1999.
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Introduction
HUD conducted a Public Housing Management Assessment Program review in 1996; however,
there were no findings. This was the latest HUD review.
We conducted our audit according to generally accepted government audit standards.
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Introduction
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Finding 1
Procurement Needed Improvement
The Authority’s procurement methods and contract administration needed improvement.
Management did not ensure that procurement was conducted in compliance with HUD and local
requirements. As a result, contract solicitations and awards did not meet related guidelines;
records lacked sufficient documentation of procurement histories; and, procurements did not
always promote fair and open competition. The Authority had no assurance that it received
services under non-competitive contracts at the most advantageous cost or from the most
qualified source. Furthermore, the Authority did not always follow its contract administration
procedures. Contract administrators did not always monitor contracts or approve payments based
on contractor performance.
Title 24 of the Code of Federal Regulations (CFR), part
Criteria 85.36 allows agencies to use their own procurement
procedures if they conform to applicable HUD requirements
and do not restrict full and open competition. The
Authority’s procurement policy dated April 15, 1997,
complied with HUD requirements and, in some cases, was
more stringent. The Authority established a $25,000 small
purchase threshold. Procurements between the range of
$10,000 and $25,000 required three written quotes. All
contracts above $25,000 required Board approval.
The Authority’s procurement policy required all
transactions to be supported by sufficient documentation of
the history of the procurement, a cost or price analysis, and
an independent cost estimate for procurements above the
small purchase limit ($25,000). The Board designated the
Executive Director as the Contracting Officer, who was
responsible for ensuring that procedures were in compliance
with HUD and Authority policies.
The Authority’s contract register listed 91 contracts valued
at over $4 million. We reviewed a judgmental sample of 12
contracts having a contract value of $3.5 million and
contract payments totaling $1.7 million. We selected the
contracts based on complaint issues and large dollar values.
We found one or more deficiencies for 10 contracts.
Appendix B summarizes the deficiencies by contract.
Generally, we noted that: many procurements lacked
competition, adequate procurement records were not
maintained, contract administration procedures were not
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Finding 1
followed, performance and payments were not administered
properly, and the contract register needed revision.
Procurement guidelines allow non-competitive procedures
Procurements lacked only when the award of a contract is not feasible using
competition alternative procedures and one of the following applies: (1)
the item is available only from a single source; (2) an
emergency exists and the need cannot be met through any
other procurement methods; (3) HUD authorizes non-
competitive proposals; or, (4) competition is determined
inadequate. HUD Handbook 7460.8 Rev 1 describes an
emergency as a situation that would otherwise cause injury
to the PHA, as may arise by reason of a flood, earthquake,
epidemic, riot, equipment failure, or similar event. Non-
competitive procurements require written justification and
the Contracting Officer’s approval. A cost analysis is
required since there is no price competition in
noncompetitive proposals.
The following examples summarize the Authority’s
procurement actions that hindered competition.
Appearance of Favoritism
MIS Contract - In April 1998, the Executive Director
declared an emergency in the Management Information
Systems (MIS) Department. He fired the Information
Systems Analyst, who was the only MIS employee at that
time. The Authority issued a $22,000 purchase order1 for
a MIS system analysis from April 3, 1998 to June 2, 1998.
The Authority’s records provided minimal support for the
emergency conditions. According to Authority staff, the
emergency was a result of MIS security issues, lack of
documentation for operations, and software conversion
problems.
The Authority did not obtain three written quotes or
perform a cost analysis. The Executive Director told us he
discussed the MIS problems with other Housing
Authorities, Commissioners, and City of St. Petersburg
officials, and selected the contractor based on qualifications
1 The Authority considered this purchase order a contract.
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Finding 1
and availability to conduct an assessment of the MIS
Department. However, the Authority’s records contained
no written basis for contractor selection or justification for
the non-competitive procurement. The contractor told us
that he met the Executive Director at a business function.
He said he later contacted the Executive Director and
presented an overview of his company and his
qualifications. He said that during their second meeting, the
Executive Director asked if his firm could do an assessment
of the Authority’s MIS Department.
On April 22, 1998, the contractor provided his preliminary
findings and solutions to the Finance Committee of the
Board of Commissioners. The deficiencies required 2
additional months to stabilize, analyze and develop
documentation for the Authority’s MIS system. The Board
adopted a resolution approving the additional two months’
work and increasing the contract amount to $45,000.
After the 4 month period expired, the contractor continued
to work for another 4 months. No written extensions
existed for this additional period. In total, the contractor
received $63,768.
We concluded the condition of the MIS Department did not
meet the requirements for an emergency, non-competitive
procurement. The Authority staff prepared a chronology of
the MIS history for the Board after we began our review.
The information showed problems occurred as early as
January 1997. Therefore, it was not a situation that caused
unexpected and unforeseen needs. There was no threat to
life, health, or public safety which required immediate
action. The Authority should have followed competitive
procedures.
Management Contract - On August 1, 1998, the Authority
entered into a non-competitive interim agreement for
management of James Park, Clearview Park, and the
scattered sites. According to Authority staff, this was done
because the Authority’s property managers had resigned
and the selected firm was already managing Jordan Park.
They saw an opportunity to privatize management of these
sites. No written justification for the non-competitive
procurement or contractor selection existed in the contract
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files. In addition, the Authority did not perform a cost
analysis or obtain Board approval for the $83,332 contract.
The contractor provided services from August through
November 1998.
Again, this situation did not warrant non-competitive award.
The Authority should have followed competitive
procedures to obtain the services at the most advantageous
cost and from the most qualified source.
Canceled Solicitations
If changes are required to a solicitation after issuance but
before proposals are due, a written amendment to all
potential offerors who were sent the original solicitation is
required. A solicitation may be canceled and all bids
rejected if: (1) the solicitation did not provide for
consideration of all significant factors; or (2) for good cause
when it is in the best interest of the Authority. The
Authority should document the reason for cancellation.
Also, the Authority must send notice of cancellation to all
offerors solicited and, if appropriate, explain that they will
be given an opportunity to compete on any re-solicitation or
future procurement of similar items.
MIS Contract - The Authority issued a solicitation for MIS
services in July 1998. During the pre-proposal conference,
potential bidders asked questions for clarification on several
issues. The Authority did not issue an amendment or
immediately cancel the solicitation.
The solicitation stated, “Any proposal received after the
specified time and date will not be considered…THERE
WILL BE NO EXCEPTIONS.” The Authority received
four timely proposals. However, the purchasing staff would
not accept a late and unsealed proposal from the interim
contractor, who had been providing onsite MIS services
under a non-competitive contract.
The interim contractor petitioned the Executive Director to
accept his proposal. Instead, the Executive Director
notified the contractor in writing that he canceled the
solicitation and would re-bid the work. However, the
Authority did not notify all bidders or properly document
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the reason for the cancellation in the contract file.
According to Authority staff, the Authority canceled the
solicitation because it did not address the bidders’
questions.
The Authority issued a revised solicitation in October 1998.
The interim contractor submitted the lowest bid and was
awarded the contract.
Excessive Bond and Insurance Requirements
Title 24 CFR 85.36 addresses situations considered to be
restrictive of competition. They include placing
unreasonable requirements on firms in order for them to
qualify to do business and requiring excessive bonding.
Management Contract - The Authority issued a solicitation
in August 1998 for private management of James Park,
Clearview Park, and the scattered sites. The interim
contractor, who was managing the sites under a non-
competitive agreement, submitted the only proposal. The
Authority sent potential bidders a survey to determine why
no proposals were submitted. Several bidders, including the
interim contractor, objected to the bond and insurance
requirements and stated they were not necessary for a
management contract. Two firms responded in writing that
they would submit bids if the Authority changed the
requirements and specifically requested notification of
future solicitations.
The Authority drafted an amendment that lessened the
insurance and bonding requirements but did not issue it to
bidders. Instead, the Authority canceled the solicitation and
re-bid the work. However, the Authority did not properly
notify all bidders or explain that the bond and insurance
requirements would be revised in a new solicitation. We
contacted the two firms mentioned above, and they were
not aware that the solicitation was canceled and a new one
issued. Also, the Authority did not respond to their letters
which clearly showed interest in the contract.
The Authority’s procurement policy states that contracts
Procurement records and modifications should be sufficiently documented to
not adequate show the history of the procurement, the method of
procurement, the selection of the contract type, the
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rationale for selecting or rejecting offers, and the basis for
the contract price. Additionally, the documentation should
summarize the results of negotiations and explain the basis
of the award decision.
We found that the Authority did not document complete
procurement histories in six cases. In four cases, the
Authority did not document the basis for contractor
selection. Additionally, contract files were missing bid
evaluation sheets for one contract and the bid packages for
another.
Although the Authority’s procurement policy provides
Performance and proper guidance, Authority staff did not always follow
payments were not contract administration procedures. Contract administrators
administered properly did not always monitor contracts or approve payments
based on contractor performance. Six of the 12 contracts
reviewed had deficiencies.
The following examples highlight some of the contract
administration problems.
Contract Administrators did not monitor performance
The contract administrators did not always approve
payments based on contractor performance. The files did
not document that the Authority monitored the contracts
and ensured that performance was complete. In some cases,
the Authority did not require monthly invoices, and contract
administrators did not approve contract payments or
provide guidance to the accounting department regarding
payments. As a result, the Authority made payments
without reviewing and/or approving contractor
performance.
One contract, awarded December 1, 1998 for $89,706,
required invoices be supported by a monthly report
“detailing activity … project status and any other
information as required.” The Authority had not received
any of the required progress reports. Since the contractor
did not submit the required monthly reports, there was no
documentation of the Authority’s evaluation of the
contractor’s performance or that deliverables were met. We
discussed the lack of progress reports with the
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Finding 1
designated contract administrator, who explained that the
contractor provided oral updates to the Authority and the
Board of Commissioners.
In another case, the Authority held private management
contracts totaling over $1 million with one contractor. The
contracts did not require invoices but did require monthly
progress reports. The contractor submitted the monthly
reports, but there was no documentation that payments
were based on the information contained in these reports.
The contract administrator did not approve payments or
provide the accounting department any guidance for making
the payments. The accounting manager told us she paid the
contractor based on her interpretation of the contract
requirements. There was no evidence that the Authority
monitored the contractor’s performance or
approved/disapproved payments totaling over $625,000 to
this contractor in accordance with the contract terms. We
discussed the lack of invoices with the designated contract
administrator. She told us that the contractor had a verbal
agreement with the former Director of Finance for
payments. She said that future contracts would require
invoices.
Contract Payments Exceeded Contract Amounts
The Authority’s contract administrators did not always
review and approve contract payments. This resulted in
inaccurate payments and overpayments to contractors.
The Authority overpaid one contractor approximately
$45,000 under an interim contract that ran from August
through November 1998. The overpayment resulted
because the contract did not require invoices and the
contract administrator did not oversee payments. The
contract required that any unearned funds at the end of the
contract term be refunded to the Authority within 15 days.
The Authority was not aware of the overpayment and did
not request a refund at the end of the contract term. After
awarding this firm another contract on December 1, 1998,
the Authority continued to overpay the contractor. After
we discussed the overpayment with Authority staff, the
interim Director of Finance discontinued payments to
recoup the overpaid amount.
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In another case, the Authority had a $45,000 interim
agreement with a contractor from April through July 1998.
The Authority continued to receive services and pay the
contractor through November 1998, yet no contract
extension existed. On December 1, 1998, the Authority
awarded the firm a 1 year contract. Although the
contractor submitted invoices to the Director of Finance,
the Authority made payments without the designated
contract administrator’s approval and documentation that
work was performed in accordance with the contract.
For another contract, the contract administrator did not take
previous amounts paid into account when he approved
invoices. This resulted in an overpayment of $5,817. We
brought the matter to the attention of the newly hired
contract administrator who took appropriate action.
Contract Continued Despite Unacceptable Performance
The Authority awarded a roofing contract for $130,680
without obtaining proper background information and
reviewing the contractor’s past performance. The lowest
bidder was awarded the contract based on price. The
required work was to be completed in 150 days.
An undisclosed, unapproved subcontractor performed the
majority of the work, who the contractor misrepresented as
an employee of its firm. The appointed contract
administrator noted numerous performance problems:
• roofing related leaks and ceiling damage;
• punctured refrigerant lines to the a/c units;
• roofers fell through ceilings;
• fraternization with female residents;
• consumption of alcoholic beverages on
Authority property;
• slow response or failure to make repairs; and,
• no workers onsite for several days at the time.
The contract file contained documentation showing the
Authority’s interest in terminating the contract early on due
to these problems. However, the Authority did not
terminate the contract until just before the scheduled date of
completion. We discussed this with the Executive
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Director, who said he was responsible for allowing the
contract to continue because the Authority was trying to
promote a minority firm.
The contractor submitted three Applications and
Certificates for Payment. The contractor certified that the
work had been completed in accordance with the contract
and that all debts had been paid for work for which previous
Certificates for Payment were issued and payments
received. After the contract was terminated, the Authority
found that the contractor did not pay two vendors and the
subcontractor. The subcontractor is currently suing the
contractor for nonpayment.
The Authority was responsible for reviewing the
contractor’s payroll reports to ensure that the correct wage
rates were paid and for resolving any discrepancies. The
Authority withheld $15,000 from the last contract payment
due to potential Davis Bacon Act violations. We discussed
this with Authority officials and neither they nor the
contract file provided further documentation on whether the
issue was resolved.
Failure to Use Labor and Material Payment/Performance
Bonds
The roofing contract required a Labor and Material
Payment Bond and a Performance Bond. A payment bond
is to assure payment of all persons supplying labor and
material in the execution of the work provided for in the
contract. A performance bond is to secure fulfillment of all
the contractor’s obligations under a contract.
The contract file documented that the contractor did not
pay a vendor for materials. However, the Authority did not
use the Labor and Material Payment Bond. Instead, the
Authority paid the vendor and reduced the contract amount
by $21,925. We discussed the issue with Authority
officials. The current Contract Administrator told us that
the Authority was not entitled to use the Labor and Material
Payment Bond after paying the vendor. In addition, the
Authority did not use the Performance Bond when the
contractor failed to complete the required work. Instead,
the Authority awarded another roofing contractor
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$97,680 for completion of the outstanding work. Authority
officials told us that the former Contract Administrator
decided to proceed in this manner. There is no
documentation in the contract files that indicates that the
Authority consulted its attorney regarding its bond rights.
The Authority spent over 18 months and $244,884 on the
roofing project that was estimated to take 150 days and cost
$140,870.
Housing authorities must have a system to periodically
Contract register monitor and assess the performance of procurement
needed revision operations. The Authority had a contract register; however,
it was not complete or current. Authority staff
acknowledged the deficiencies and said they were
implementing controls for updating and maintaining the
contract register.
Authority officials took exception to the statements of
Authority comments favoritism and hindered competition. However, they agreed
procurement methods and contract administration needed
improvement. They stated they have taken several steps to
strengthen their process. They have developed a checklist
to better document the procurement process, updated the
contract register, and are in the process of compiling
detailed written procedures.
The Authority’s actions, if timely and fully implemented,
OIG evaluation of should improve the procurement methods and contract
Authority comments administration.
Recommendations We recommend you:
1A. Assure the Authority establishes detailed written
procedures and assigns responsibility to: (1) ensure
contract solicitations and awards meet HUD
requirements as well as its own procurement policy,
(2) monitor contractor performance and payments,
and (3) implement a quality control system to
monitor the contracting process.
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1B. Monitor the Authority’s procurement and contract
administration process during your next monitoring
visit to ensure the Authority’s procedures meet
HUD requirements.
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Finding 2
Management of Section 8 Program Needed
Improvement
The Authority had not effectively administered its Section 8 Program for many years. It had not
established financial and management controls to monitor its budget, cash reserves, or leasing
rates. The problems appeared to stem, at least in part, from a lack of coordination between the
finance and program staff. Consequently, the Authority’s Section 8 bank accounts were in a
deficit position and its operating reserves were depleted. Furthermore, in fiscal year 1999, the
Authority lost an opportunity to house an additional 181 families and to earn additional income of
$93,346. Instead, the Authority accumulated excess funds of $857,585 which it had to return to
HUD. The Authority was already in debt to HUD for $173,683 for its 1997 and 1998 Moderate
Rehabilitation Program, and had overspent its 1999 Moderate Rehabilitation (MOD Rehab)
Program by $131,857 and its 2000 Section 8 Program by $188,849.
Directive Number 94-64, Revised Submission Requirements
Criteria for Requisition for Partial Payment of HUD Annual
Contributions, Paragraph IV, B, 2 provides that revised
budgets and requisitions must be completed and submitted
to the HUD Field Office if the housing authority determines
that the amount of funding reflected in the initial budget
submission and the amount of annual contributions
requested on the annual requisition will cause it to receive
advances in excess of 5 percent of the actual annual
contributions required for the year.
Paragraph 8-2d(1) of HUD’s Administrative Practices
Handbook for Section 8, Directive Number 7420.7,
provides that a housing authority must ensure that projected
administrative fees and the Operating Reserve will cover all
projected costs of efficient and effective program
administration through remaining ACC terms.
Paragraph 8-6d of HUD’s Administrative Practices
Handbook for Section 8, Directive Number 7420.7,
provides that housing authorities must estimate their
minimum requirements for annual contributions accurately
to achieve the highest level of cash management. They must
limit the amounts requisitioned to funds absolutely needed
to minimize interest costs to the Government.
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Finding 2
The Authority received $10,433,022 during fiscal year 1999
Leasing goals for 1999 to operate its Section 8 Program - $10,059,292 from
were not met HUD’s Certificate, Voucher and MOD Rehab Programs;
$337,463 from other public housing authorities to house
residents from their jurisdictions (portables); and $36,267
from income earned from investments. The Authority was
to use these funds to lease an average of 1,968 units per
month, pay portables expenses, and pay administrative and
audit fees. However, it fell short of its leasing goals during
the fiscal year. The lease rate averaged about 90 percent for
the first 8 months of the fiscal year and 96 percent for the
remainder of the year. Although the leasing rate was down
by about 10 percent, the Authority took no action to revise
its budgets to reduce the amount of funds it would receive
from HUD. Thus, it continued to receive monthly
allotments of Section 8 funds from HUD based on the
obsolete budgets, and began accumulating excess funds. By
the end of the fiscal year, it had accumulated $857,585 in
Federal funds it did not need.
The Authority could not show that it did any analysis
comparing the number of units it was leasing with the funds
it had available or how much it was costing to lease a unit.
Without this information, it could not effectively manage the
program. According to the Section 8 Manager, who
worked under the Director of Finance, he was not aware of
any analysis or controls and he never discussed the
availability of the excess funds with the Finance Director.
By not monitoring its availability of funds, the Authority
was not aware it had available funds of $71,466 per month
to house additional families. Since the average cost to lease
a unit during 1999 was $396, an additional 181 families
could have been served. At March 31, 1999, the Authority
had over 900 applicants seeking housing assistance.
The Authority also lost an opportunity to earn
The Authority lost administrative fees of $93,346 by not leasing the additional
income of $93,346. 181 units. This is based on an average fee of $43 per unit
per month. Had the Authority earned the additional
administrative fees, it would have realized a net income
from operations for the year, instead of a loss of $58,744.
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Finding 2
The Authority’s inability to fully utilize its Section 8 funds
Section 8 funds were has been long standing. It has had to repay HUD $760,515
in a deficit position for under utilization of its 1995, 1996, and 1997 MOD
Rehab Program. As of our audit, it owed HUD $173,683
for its 1997 and 1998 MOD Rehab program and $857,585
for its 1999 programs. The Authority also made MOD
Rehab payments of $131,857 during 1999 that exceeded the
HUD approved budget, and overspent the first five months
of its current certificate and voucher program budgets by
$188,849. At March 31, 1999, the Authority had $836,932
in its Section 8 bank accounts which was not enough to pay
its current debt to HUD.
The Authority did not have a documented system to support
The Authority did not its allocation of costs to the Section 8 Program. Although
support its allocation the allocations were made by journal vouchers, we could
of administrative costs not determine the basis for the entries. The interim Finance
Director said there was no basis for the allocations, but only
instructions provided by the former director. He said the
former Finance Director made the allocations to suit his
needs.
The Section 8 Certificate and Voucher Programs incurred a
$58,744 loss in fiscal year 1999. The losses resulted from a
significant increase of $278,870 in administrative expenses
during fiscal year 1999 while income increased by only
$4,646. According to the accounting manager, the increase
in expenses occurred primarily when the Authority
privatized three of its conventional developments and
prorated the overhead of those developments to the Section
8 and other remaining programs. Salary increases to its
Section 8 employees also contributed to the increase.
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Finding 2
Although administrative expenses increased significantly,
there was no appreciable increase in the Section 8 activities.
For example, administrative salaries increased from
$440,019 in 1998 to $590,479 without any significant
increase in the number of units leased. Office rent charged
to the Section 8 Program increased from $63,129 in 1998 to
$94,489 in 1999. The space occupied by the Section 8 staff
did not change.
The combination of missed leasing goals, unrealized income
from fees, budget overruns, and overcharging administrative
costs have devastated the Section 8 operating reserves.
Consequently, at March 31, 1999, the Authority’s Section
8 operating reserves for its voucher and certificate programs
were $0. This deficit was the result of a long standing
negative reserve in the certificate program and losses from
operations of $58,744 for both programs during fiscal year
1999.
The problems in this program can be attributed, at least in
part, to the lack of coordination between the prior Section 8
manager and the former Finance Director. According to the
manager, the Finance Director, to whom he reported, did
not keep him apprised of the status of the Section 8 funds
nor make him aware when the Authority had excess funds
available to lease additional units. In June 1999, the
Authority hired a Director for its Section 8 Program. The
new Section 8 Director and the interim Finance Director are
currently working together to improve the program.
Authority officials agreed with the finding and said they had
Authority comments taken several steps to improve management of the Section 8
program. They reorganized the management structure to
permit greater coordination between the Section 8 and
Finance Departments, contracted with a fee accountant to
prepare accurate budgets using leased unit data,
implemented a new spreadsheet to monitor units leased and
dollars spent, and are converting to a new software
program. They converted families in the Moderate
Rehabilitation Program to the Section 8 Certificate
Program. They also submitted year end settlement
statements which resolved the overpayments due HUD.
They will review the allocation plan to assure it reflects the
costs applicable to the various programs.
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Finding 2
The Authority’s actions, if timely and thoroughly
OIG evaluation of implemented, should improve management of the Section 8
Authority comments program. Although a new accounting system is currently
being installed, the portion that supports program tracking
and monitoring has not been fully implemented. The
Authority had not developed a cost allocation plan.
Recommendations We recommend you:
2A. Assure the Authority implements the new
accounting system or establishes additional controls
to monitor the number of units leased to the amount
of funds available.
2B. Require a quarterly accounting for the amount of
funds drawn, the number of units leased, and the
amount of funds on hand to assure the Authority is
not overdrawing funds.
2C. Assure the Authority implements an allocation plan
and assure that the costs charged to the Section 8
and other programs are applicable and supported.
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Finding 2
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Finding 3
Inadequate Controls Over Rogall Funds
The Authority did not establish adequate controls over funds received from refinancing Rogall
Congregate. As a result, the Authority did not fully document how it spent $558,262 of $670,880
received from the refinancing transaction, and lacked controls to ensure an additional $400,000 to
$900,000 it will realize over the next several years will be spent as approved by its Board. Also,
the Authority did not provide HUD an accounting for the funds as required by its Memorandum
of Understanding (MOU) with HUD, and needed to reimburse HUD for funds due.
The Authority issued bonds in 1977 to finance the
Background construction of Rogall Congregate, a 150 unit elderly low-
income housing project with a Section 8 contract. In June
1994, the Authority refinanced the existing bond issue as a
means of generating additional funds. The Authority
received $670,880 from the refinancing transaction. Also, it
will realize additional ongoing savings for several years as a
result of the reduced interest rate.
HUD approved the refinancing on March 29,1994. On June
22, 1994, HUD and the Authority executed a Memorandum
of Understanding (MOU) covering among other things the
use of the proceeds from the refinancing. The MOU
required the Authority to use the funds in accordance with a
proposal dated August 10, 1993, and to obtain HUD
approval to use the funds in any other manner.
The August 10, 1993, proposal indicated that $307,650
received at closing would be deposited with the Trustee and
allocated as capital improvements for qualifying low-income
and elderly projects. Any additional amount received at
closing would be used for other housing purposes. By
resolution dated June 16, 1994, the Board decided to use
$200,000 of the additional funds to be received for
improvements to its computer system and the balance for
low rent housing purposes at the Board’s discretion.
In accordance with the proposal, the Trustee received
$209,630 used for $307,650 at closing and deposited the funds to the
operations replacement reserve account. The Trust Indenture specified
that this fund would be used to pay the cost of
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Finding 3
extraordinary maintenance and replacements to keep the
project in sound condition.
In June 1995, the Authority requested the Trustee to send
funds to cover Rogall’s operating expenses for the year
ended March 31, 1995. The Trustee disbursed $209,630
from the replacement reserve account. There was nothing
in the Authority’s files to justify the use of the $209,630 for
operating costs.
The Authority received $363,230 from the closing and
Use of $363,230 not deposited the funds in an existing non-profit account. The
documented Authority then transferred the $363,230, in two
installments, to another account called “General Reserve
Account” (GRA) on July 21 and September 29, 1994. The
GRA also received funds from other sources which
increased the account to $689,400.
In October 1994, the Authority used the other funds and
$14,598 of the $363,230 to purchase 3 certificates of
deposit and transfer funds to another project account.
There was no evidence of Board approval to transfer the
$14,598 to the other project. The purchases and transfers
reduced the balance to $348,632. Subsequently, the
Authority disbursed the $348,632 balance to its master fund
account. As discussed in Finding 4, the Authority did not
have good accountability of master fund receipts and
disbursements.
The June 16, 1994 Board resolution stated that the funds
would be used to fund a $200,000 computer upgrade and
the balance would be used for low rent housing as
designated by the Board.
We attempted to review the propriety of the disbursements
to the master fund. However, the documentation
supporting the transactions was not sufficient to provide a
description of the use of the funds. We asked the
accounting manager to see if she could explain the purpose
of the disbursements. She reviewed the journal entries but
could not give a specific explanation. The accounting
manager said she would continue to try to determine what
the transfers to the master fund represented. She said that
the way the system was set up, it would take a substantial
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Finding 3
amount of time to trace the entries. Since we could not
determine what the transfers represented, we could not
determine if the funds had been used properly and if Board
approval had been obtained.
The proposal indicated the refunding program was
No control over structured with a debt coverage ratio of 1.10. As a result,
ongoing savings the Authority would realize additional savings throughout
the life of the refunding program. The proposal estimated
the Authority would realize savings of $422,473 from the
date of refinancing to January 1, 2007, and indicated the
savings would be allocated to capital improvements. The
June 16, 1994, Board Resolution estimated the ongoing
savings would amount to $919,752. The resolution showed
that $401,704 would be used to repay HUD for prior OIG
audit findings, and $518,048 was designated by the Board
for low income housing. The resolution also said the Board
designated amounts were subject to final approval by the
Board prior to their expenditure.
We could not find any more information about the ongoing
savings. We asked the Executive Director and other
employees if they knew about the ongoing savings and how
the Authority used the savings. None of the current
employees, including the Executive Director, were
employed at the Authority when the project was refinanced
and none of them were aware of the ongoing savings. Since
the Authority was not aware of the ongoing savings, it did
not establish controls to assure the funds were spent in
accordance with the Board resolution.
Based on the proposal, we concluded and the Executive
Director agreed, that the ongoing savings represented the
net profit the Authority earns from the operation of Rogall.
The audit report for Rogall at March 31, 1998, showed a
net income of $210,351.86. The net included depreciation
of $164,465.04, thus, the actual cash realized was over
$374,000 for the year. These funds were deposited by the
trustee in the surplus account after all other funds had been
funded. The balance in the surplus account at March 31,
1999, was $631,031.98 and all other funds were fully
funded.
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Finding 3
According to the Board resolution, the Authority was to use
Funds not paid to a portion of the savings to pay HUD the money it owed
HUD from the 1992 HUD OIG audit report. The Authority owed
HUD $389,216 because it over drew its operating subsidy
for 1991 and 1992. The Authority executed a repayment
plan with HUD to pay the $389,216 back to HUD. HUD
agreed to the repayment plan because at the time the
Authority did not have the funds to repay HUD the full
amount. The Authority made payments in accordance with
the repayment plan except for its last 2 payments. The
Authority was late making its April 1, 1998 payment and
had not paid its April 1, 1999 payment. At July 31, 1999,
the balance due was $243,260.
The MOU required the Authority to provide annual reports
Reports not provided to HUD (beginning July 1, 1994), showing the amount and
to HUD description of the expenditures until the funds had been
spent. Furthermore, the MOU required the Authority to
arrange for the inclusion of such funds in the annual audit
reports.
There was nothing in the Authority’s files to show it had
provided HUD annual reports providing descriptions and
amounts of expenditures of the refinancing proceeds. Also,
the annual audit reports did not separately account for the
receipt and expenditure of the funds.
The Authority provided documentation which showed the
Authority comments $209,630 was used for extraordinary maintenance,
replacement of non expendable equipment and property
betterments. Authority officials stated they were in the
process of gathering documentation and information
supporting the use of $363,230. They agreed the ongoing
savings would be spent in accordance with HUD
requirements and Board resolution. They repaid HUD the
remaining balance for the prior OIG finding concerning
overdrawn operating subsidy. They agreed to provide HUD
a separate annual report of the use of the ongoing savings.
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Finding 3
The Authority’s actions should resolve the issues.
OIG evaluation of
Authority comments
We recommend you:
Recommendations
3A. Review the Authority’s documentation supporting
the $363,230 transferred to the other project and
master fund. The documentation should show that
the funds were used in accordance with the Board
resolution.
3B. Establish a report format for use of the ongoing
savings.
3C. Assure the Authority uses the ongoing savings in
accordance with HUD and Board requirements.
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Finding 3
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Finding 4
Inappropriate Transfers of Public Housing
Funds From Master Fund
The Authority’s master fund did not meet HUD requirements, did not provide a clear accounting
for cash transactions, and allowed improper use of funds. We identified misuse of the fund in a
1992 audit. HUD instructed the Authority to discontinue its use and the Authority agreed to do
so. Despite such agreement, the fund was still in use and transfers of public housing funds had
continued to be made for another 7 years with virtually no accountability. At September 30,
1999, the Authority had misused at least $410,000 that we could identify.
Section 9 (C) of the Annual Contributions Contract (ACC),
Criteria Depository Agreement and General Fund, provides that the
Authority shall maintain records that identify the source and
application of funds in such a manner as to allow HUD to
determine that all funds are and have been expended in
accordance with each specific program regulation and
requirement. Funds may be withdrawn from the general
fund only for: (1) the payment of costs of development and
operation of the projects under the ACC; (2) the purchase
of investment securities approved by HUD; and (3) such
other purposes as may be specifically approved by HUD.
Program funds are not fungible; withdrawals shall not be
made for a specific program in excess of the funds available
for that program.
Section 10 (B) of the ACC, Pooling of Funds, allows the
Authority to deposit funds from Public Housing operations
and other projects or enterprises into an account to pay joint
expenses. Section 10 (C) provides, however, that the
Authority shall not withdraw from any of the funds or
accounts authorized under Section 10 amounts for projects
under the ACC or for other projects or enterprises, in
excess of the amount on deposit in respect thereto.
Section 13 of the Consolidated Annual Contributions
Contract for the Section 8 program provides that the
Authority may only withdraw deposited program receipts
for use in connection with the program in accordance with
HUD requirements.
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Finding 4
Our prior audit report, issued December 9, 1992, cited the
Prior finding not Authority for using a revolving fund to conceal the misuse
resolved of housing authority funds. We demonstrated how the
Authority’s action violated the ACC, the Section 8
contracts, and HUD’s Low-Rent Housing Accounting
Handbook. We recommended closing the master fund,
transferring the assets to appropriate program accounts, and
establishing and operating an account for payment of joint
expenses in accordance with HUD requirements. OIG
closed the finding in April 1993 based on the Authority’s
promise to close the fund and open another account for
payment of joint expenses only in accordance with
regulatory requirements. Our current audit revealed that, in
fact, neither of these actions occurred. The Authority went
only so far as to establish a separate bank account for
receipt and disbursement of its Section 8 program funds, but
continued to pay its Section 8 administrative costs, as well
as all other expenditures, through the master fund.
The master fund is part of the Authority’s general ledger
Inappropriate and receives all public housing operating subsidies from
payments from the HUD. The fund also receives all rents from the Authority’s
master fund public housing developments and from Rogall Congregate,
a private apartment complex owned by the Authority. All
payments the Authority makes, either public or private, are
made from the master fund The rents from Rogall are
accumulated and paid to a bond trustee at the end of the
month. All other programs, for which payments are made,
replenish the master fund generally on a reimbursable basis.
Therefore, any inappropriate payments made from the
master fund would generally come from the operating
subsidy provided for public housing. We identified
inappropriate expenditures of over $410,000 as follows:
Taxpayers subsidize over $300,000 for a private enterprise
According to the trust indenture for Rogall Congregate, the
trustee is entitled to receive Section 8 operating subsidies
directly from HUD and all the rents the Authority collects
from Rogall residents. The trustee reimburses the Authority
for the Authority’s expenses associated with managing
Rogall.
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Finding 4
In April 1999, HUD stopped providing monthly Section 8
subsidies to the trustee because the Authority failed to
provide HUD with required Section 8 tenant data. The
problem appeared to be a software glitch that the Authority
still had not resolved as of September 30, 1999. When
HUD stopped paying the trustee, the trustee stopped
reimbursing the Authority for its expenses. The Authority
continued to incur the operating expenses associated with
Rogall, but inappropriately paid for them from the master
fund. The costs of operating Rogall for the period from
April to September, 1999 were approximately $300,000.
Authority improperly used $58,744 to fund Section 8
operating deficit
As noted in Finding 2, the Authority did not earn enough
administrative fees to cover its cost to operate the Section 8
Program during fiscal year 1999. According to the financial
statements, the Authority spent $1,048,224 to run the
program. The Authority earned administrative fees of only
$989,480, resulting in a deficit of $58,744 which was
improperly absorbed by other housing programs.
Authority misspent $52,174 for recreation program
activities
The Authority paid $52,174 from the master fund for
administrative costs of its recreational program for fiscal
year 1998. These costs were to have been paid from
donations from the City of St. Petersburg. The donations
were contingent upon the Authority paying its obligations to
the City (Payments in lieu of taxes or PILOT). At March
31, 1999, the Authority had not made its PILOT payment to
the City and therefore was not in a position to receive the
donation.
We reviewed various accounts making up the master fund
Master fund account at March 31, 1999. We limited our review because the
balances were not accounting system was cumbersome and the Authority had
auditable not reconciled the accounts. Tracking historic data was
very time consuming because the audit trail was virtually
non-existent. We noted that the master fund accounts
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Finding 4
included receivables and payables for other programs and
that the balances in some of the accounts appeared
erroneous. Two accounts had unusually large balances:
Account Balance in Master Fund
Interfund with General Fund $2,749,533 (Payable)
Interfund with Rogall $2,510,452
(Receivable)
Interfund with General Fund
The General Fund has owned the Authority’s administration
building since June 1995, and has charged rent to the
various programs on a prorated basis. Although the rent is
charged, the programs have not paid the rent and the
payable has continued to accumulate at a rate of $144,000
per year for a total of $684,000 as of March 31, 1999. We
were unable to readily determine the propriety of the
remaining payable balance of $2,065,533 as this payable had
accumulated over many years.
Interfund with Rogall
Most of the $2,510,452 receivable had been on the
Authority’s books for several years. We attempted to
compare the $2.5 million receivable to payables on Rogall’s
records. Rogall’s records, however, did not show any
payable to the interfund account.
If the Authority continues to use the master fund as it has
in the past, HUD will be unable to assure that public funds
are being spent properly.
Authority officials agreed with the finding, and stated they
Authority comments are in the process of reconciling the receivables and
payables. In addition, the Authority has replaced the master
fund with a revolving fund, and is in the process of
converting to a new computer system. Also, the Authority
has reimbursed $410,000 to the public housing program.
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Finding 4
The Authority’s actions, if timely and adequately
OIG evaluation of implemented, should resolve the issues.
Authority comments
Recommendations We recommend you:
4A. Assure the Authority reconciles the receivables and
payables in the interfund accounts, makes
appropriate adjustments, and closes the master fund.
4B. Assure the Authority establishes a revolving fund
accounting system to process joint costs only. The
system should have its own general ledger and be
reconciled each month.
4C. Assure the Authority establishes controls to ensure
the Authority pays only specific program costs from
funds provided for the specific program.
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Finding 4
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Management Controls
In planning and performing our audit, we obtained an understanding of the management controls
that were relevant to our audit objectives. We considered the Authority’s management control
systems to determine our auditing procedures and not to provide assurance on management
controls. Management is responsible for establishing effective management controls.
Management controls include the organization plan, methods, and procedures adopted to ensure
that goals are met. Management controls include the processes for planning, organizing,
directing, and controlling program operations. They include the systems for measuring, reporting,
and monitoring program performance.
We determined the following management control categories
Relevant management were relevant to our audit objectives:
controls
• Procurement and contracting
• Accounts payable for PILOT
• Accounts payable to HUD
• Section 8 funds requisitioned
• Use of funds restricted by ACC
We obtained an understanding of the Authority’s
procedures and HUD requirements, assessed control risk,
and performed various substantive tests of the controls.
A significant weakness exists if management controls do not
give reasonable assurance that the entity’s goals and
objectives are met; that resource use is consistent with laws,
regulations, and policies; that resources are safeguarded
against waste, loss, and misuse; and that reliable data are
obtained, maintained, and fairly disclosed in reports.
Based on our review, we believe significant weaknesses
Significant weaknesses exist in all areas reviewed. These weaknesses are discussed
in the Findings of this report.
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Management Controls
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Follow-Up On Prior Audits
The Independent Auditor’s report for the year ended March 31, 1998, had no findings directly
related to our audit objective or results. We reviewed the status of the 1998 findings as of March
31, 1999. Two findings remained open. One finding noted deficiencies in maintenance of low
income and Section 8 tenant files. The other finding showed that the Authority did not submit the
required HUD report for tenant accounts receivable.
An Office of Inspector General audit report issued December 9, 1992, addressed deficiencies in
13 findings. Recommendations for three of the findings had extended repayment dates and
remained open. The Authority was current with its repayment plan for two of the findings. For
the third finding, it was late making its April 1, 1998, payment and had not made its April 1, 1999,
payment. The results of our review of the late repayment are addressed in Finding 3 of this
report.
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Follow-Up On Prior Audits
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Appendix A
Schedule Of Unsupported Costs
Recommendation Unsupported2
3B $363,230
2 Unsupported amounts do not obviously violate law, contract, policy, or regulation, but warrant being contested for
various reasons, such as the lack of satisfactory documentation to support eligibility and HUD approval.
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Schedule Of Unsupported Costs
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Appendix B
Summary of Procurement Deficiencies
Contract Vendor A B C D E F G H I J K L M N O P Q R
Number
Miracle Workers Computers X X X X X X X
98-040 Miracle Workers Computers X X X X X X
97-003 Renker, Eich, Parks Architect X
96-017 Salem, Saxon,Nielsen, P.A.
98-021 Tab Glass X
H.J. Russell-James/Clearview X X X X X X X X X X
98-037 H.J. Russell-James/Clearview X X X X
98-019 H.J. Russell- Jordan Park X X X X
97-110 Priede-Mal X X X X
98-101 Sylla Inc. X X X X
98-027 Greater Miami Neighborhoods
97-107 MontgomeryKone X
TOTAL 2 3 2 6 3 1 1 6 4 1 1 1 4 1 1 3 1 1
Solicitation and Award Deficiencies
A Inappropriate procurement method.
B Inadequate competition.
C Sole-source contract not justified.
D No independent cost and/or price analysis.
E Contract not approved by Board before executed.
F No review of contractor's past performance before award
.
G Contract did not include all required clauses.
Inadequate Procurement Records
H File did not show complete procurement history.
I File did not document the basis for contractor selection.
J File did not include all the bid evaluation sheets.
K File did not include all the bid packages received.
Inadequate Payment/Contract Administration
L Payment made without contract.
M Payment made without proper PHA authorization.
N Payment made without receipt/review of required monthly reports.
O Payment made above the contract amount.
P Payment made without invoice.
Q Contract not terminated timely when contract requirements were not met.
R Performance/Payment bonds not utilized by PHA.
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Summary of Procurement Deficiencies
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Appendix C
Authority Comments
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Authority Comments
Audit of the St. Petersburg Housing Authority (SPHA)
DRAFT RESPONSE
The auditors’ comments, time and effort are very much appreciated. All comments will be
used constructively to strengthen the procedures and systems used to monitor procurement
and contracting activities. However, SPHA takes exception with the statements of
favoritism and of hindering competition. No favoritism was ever shown, and competition
was not hindered, deliberately or otherwise.
Finding 1 – PROCUREMENT NEEDS IMPROVEMENT
The Authority is in agreement that its procurement methods and contract administration
needed improvement and refinement. A system has been put in place to assure proper
documentation is included in each procurement and contract file, and that proper contract
administration is carried out. The Contract Register has been updated, and is in use to assist
in procurement planning and proper contract administration. The General Services
Department is in the process of compiling detailed written procedures that describe how the
requirements of the Procurement Policy will be carried out.
Additionally, the Authority has taken steps to ensure that sufficient documentation of the
history of the procurement is maintained through the Procurement Checklist.
Procurements Lacked Competition
Although SPHA is not in agreement that its procurements lacked or hindered competition
we acknowledge the Auditors’ finding and have taken steps to avoid this appearance in the
future. SPHA follows sole-source procurement procedures when applicable and will
provide better documentation of these procurements in the future.
Favoritism
SPHA is not in agreement that favoritism was ever shown in any procurement. To avoid the
appearance of this in the future we will provide better documentation of our procurements.
The Executive Director has documented that no prior relationship of a business or personal
nature existed between him and any of the principals of Miracle Workers, specifically the
firm’s president.
Declaration of Emergency: SPHA maintains that the declaration of an emergency in the MIS
department was justified and met HUD requirements. Records do exist documenting the
declaration of an emergency by the Executive Director, however, a memo should have been
included in the procurement file for the emergency contract. Attached is a memo dated April
2, 1998 to the Information Systems Analyst outlining the conditions that constituted a
declaration of an emergency. Quotes were obtained for a systems analysis of the MIS
department, but were not included in the interim MIS contract file. Based on these quotes
the quote of $22,000 for the initial 2-month period
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Authority Comments
was determined to be reasonable. The Executive Director did not make a unilateral decision
without benefit of cost comparison.
MIS Contract: A purchase order was issued for emergency MIS Consulting services in an
amount not-to-exceed $22,000. Per SPHA’s Procurement Policy, the threshold required
for formal Board approval is $25,000, and the purchase order did not exceed that amount.
Later in the month of April, the MIS consultant advised from his analysis of the department,
that another 2 months of services would be required to bring the department to an
acceptable level of operation. At the April, 1998 Finance Committee meeting and the April
23, 1998 regular Board meeting, the severity of the situation was discussed, and Resolution
#1633 was passed, authorizing an additional 2 month period for a total price not to exceed
$45,000. SPHA did formally bid the work.
Management Contract: It was the intent of SPHA in 1998 to privatize all property
management functions. After the resignation of the manager for James Park, Clearview Park
and the Scattered Sites, the Authority was managing the properties with in-house staff, while
attempting to hire a manager. The timing was right to continue to privatize the property
management function. The Executive Director contacted the HUD Miami office to obtain
permission to award a noncompetitive contract for James/Clearview/Scattered Sites, to H. J.
Russell and Company, as they were already competitively procured to manage the Jordan
Park development. While a difference of opinion exists as to whether or not approval was
granted, SPHA maintains that verbal approval was received. The Housing Authority has
taken steps to ensure that all required documentation is included in all contract and
procurement files, i.e. contract and procurement checklists.
Canceled Solicitations
SPHA contends that all cancelled solicitations were necessary and justified. We agree better
documentation is needed. The Authority now complies with the requirements for
cancellation of solicitations.
MIS Contract: The Authority agrees that RFP 99-022 should have been amended to respond
to questions and issues brought up by potential bidders at the pre-proposal conference.
However, as an amendment was not drafted for this solicitation, a reissued solicitation was
advertised which was substantially modified from the original version, but included
clarification to questions raised earlier by bidders.
Excessive Bond and Insurance Requirements
The Housing Authority maintains that it did not place unreasonable requirements on firms
in order for them to qualify to do business. In only one instance, RFP 98-024, Private
Management of James/Clearview/Scattered Sites, the bonding requirement in was included
in error, but was corrected in the subsequent solicitation. Therefore, it should not be said
that SPHA routinely restricts competition by placing unreasonable
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Authority Comments
requirements on firms in order for them to qualify to do business and requiring excessive
bonding.
We request that this reference be removed.
Procurement Records Not Adequate
The General Service Department has developed a Contract Checklist, a Procurement
Checklist, and an approval process, which is now being followed for all procurements and
contracts, to ensure that proper and complete documentation is included in every file. See
Recommendation 1A.
Performance and Payments Were Not Administered Properly
The Director of General Services appreciates the OIG Auditor’s analysis of this function and
will use it as a basis to provide the best possible administration of SPHA’s contracts. We
are more than willing to make any adjustments and corrections in our operations that will
improve our performance and our ability to better serve our residents. See Recommendation
1B.
Contract Continued Despite Unacceptable Performance
SPHA acknowledges that it did work with one contractor extensively to complete the scope
of work for a roofing project. Priede-Mal Constructors were given several chances to correct
deficiencies in their work. These actions were taken to assist this minority contractor in
establishing capacity. HUD encourages, and the Board of Commissioners supports the award
of contracts to minority or women owned businesses. The Housing Authority attempted to
work with this minority contractor in the hope that the firm would be able to complete the
work. Despite SPHA’s commitment to provide contracting opportunities to minority firms
whenever possible, this contract was terminated once it became apparent that the contractor
could not perform the work required.
Contract Register Needed Revision
SPHA acknowledges that the contract register is an important document and compliance tool,
and that it was not up to date at the time of the audit. The contract register has been updated,
and is in the process of being fine-tuned. The General Services department has assigned one
employee to continuously update this important document.
All overpayments to contractors have been corrected, and reimbursements have been
received.
Recommendations:
1A. Establish controls to conduct and document procurement actions in full
compliance with HUD requirements as well as its own procurement policy.
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Authority Comments
We are in agreement with this recommendation. The General Service Department has
developed and implemented a checklist system to ensure proper documentation is included
in each procurement and contract file, and that proper contract administration is carried out.
This system includes:
1) Procurement Checklist: to assist in setting up and maintaining the procurement files in
compliance with 24 CFR 85.36, HUD Handbook 7460.8 REV.1, and SPHA’s
Procurement Policy.
2) Submission Checklist for RFP’s and IFB’s: this document will ensure that each proposal
received in response to a solicitation includes all required documentation.
3) Contract Checklist(s): designed for both construction and non-construction type
contracts, this list briefly discusses the terms of the contract, required HUD and SPHA
forms, including Davis-Bacon compliance, if applicable, and the process for approving
invoices and change orders. The Contract Checklist is discussed with the contractor after
contract award and prior to the contract signing. The contractor must sign the document
and it is included in the contract file.
4) Sections 3 Checklist – used to ensure complete understanding of SPHA’s Section 3
policy and contractor’s obligations for compliance. The contractor must sign this
document and it is included in the contract file.
5) An approval process for the payment of invoices and submission and approval of change
orders: This process is in the form of a memorandum, and is presented and discussed in
detail at contract signing and/ or at the pre-construction conference for both construction
and non-construction contracts. The approval process will greatly enhance SPHA’s
ability to monitor and administer contracts.
This checklist system will ensure all required documentation is included in proposals, that the
contractor understands what is required per the terms of the contract, and that procurement
and contract files are complete. The Contract Register has been updated, and is in use to
assist in procurement planning and proper contract administration. The General Services
Department is in the process of compiling detailed written procedures that describe how the
requirements of the Procurement Policy will be carried out.
1B. Establish a contract administration system that monitors and assures contractor
performance under the terms of their contract.
We are in agreement with this recommendation. The Director of General Services appreciates
the OIG Auditor’s analysis of this function and will use it as a basis to provide the best
possible administration of SPHA’s contracts. The systems listed above have been
implemented, and the Contract Register is being used as a tool to ensure better contract
administration. The Housing Authority will use performance-based contracts with
deliverables, and will require monthly reporting, when applicable, in all non-construction
contracts. The contract administrator will approve invoices based on the deliverables due, and
will perform a payment analysis on the amount invoiced by the contractor. The entire
approval process has a check and balance of final review by the General Services department
to ensure that proper documentation and approvals are in place before forwarding the invoice
to the Finance department for payment.
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1C. Implement a quality control system to monitor the contracting process for
conformance with policies and procedures.
We are in agreement with this recommendation, and submit that it has been implemented with
the systems listed in 1A and 1B above.
1D. Ensure the Board of Commissioners oversees the procurement process.
The Board of Commissioners is required to approve all purchases and contracts that exceed
$25,000. When a request is received for a good or service by the General Services department,
a determination is made on whether three (3) bids, or a formal solicitation is required.
Purchases under $25,000 require three (3) bids, a cost analysis, and are monitored through
the Purchasing Agent, the Director of General Services, the Deputy Executive Director and
the Executive Director. In the case of a formal solicitation requiring Board approval, an
evaluation committee makes a recommendation to the Executive Director, and the Executive
Director makes a recommendation to the Board. The Board makes the final decision on the
award of the contract. In general, it is the duty of the Board to set policy, which is carried out
by the Executive Director. The SPHA Procurement Policy has been approved by the Board
and meets all HUD requirements.
Finding 2- THE AUTHORITY NEEDS TO IMPROVE MANAGEMENT OF ITS
SECTION 8 PROGRAM
2A. Establish controls to monitor the number of units leased to the amount of funds
available.
This recommendation is being implemented. The SPHA has reorganized its management
structure to permit greater coordination between the Section 8 and Finance departments. The
SPHA has contracted with a Fee Accountant who has experience in HUD programs and
regulations. Section 8 budgets are accurately prepared using leased unit data. A spreadsheet
has recently been implemented which allows for the monthly monitoring of units leased and
dollars spent. In addition, SPHA has recently converted to a new software program that
supports program tracking and monitoring.
2B. Provide a quarterly accounting for the number of funds drawn, the number of
units leased, and the number of funds on hand to assure the Authority is not
overdrawing funds.
The SPHA will monitor this information on a monthly basis and will provide the information
as requested. We will prepare and submit budget revisions to HUD as necessary.
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2C. Provide justification and documentation to support the $131,000 overspent in the
Moderate Rehabilitation Program.
Upon termination of the Moderate Rehabilitation program contracts, families in the Moderate
Rehabilitation program were converted to the Section 8 Certificate program. The Moderate
Rehabilitation program Year End Settlements for fiscal year ending March 31, 1998 were
revised and approved by HUD on March 6, 2000.
2D. Review its allocation of administrative costs to the Section 8 and other programs
and demonstrate that costs charged are applicable and supported.
The SPHA has reviewed the allocation to assure it reflects the costs applicable to the various
programs.
Finding 3- INADEQUATE CONTROLS OVER ROGALL FUNDS
3A. Refund the replacement reserve account $209,630 for the funds used for operations.
This has been corrected. The SPHA has provided backup and documentation to the auditor
to justify the $209,630 used for extraordinary maintenance, replacement of non-expendable
equipment and property betterment’s, not operating costs. Therefore, no refund to the
replacement reserve account is necessary.
3B. Provide documentation supporting the $363,230 transferred to the other project
and Master Fund. The documentation should show that the funds were used in
accordance with the Board resolution.
The SPHA is currently in the process of gathering the documentation and information
supporting the $363,230.
3C. Pay HUD the balance it owes for over draws of the operating subsidy ($243,260 at
March 31, 1999).
This balance has been paid to HUD and a copy of the check was provided to the auditor.
3D. Establish controls to assure expenditures of the ongoing savings are spent in
accordance with HUD and Board requirements.
All expenditures will be in accordance with HUD requirements and will be supported by Board
resolution.
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3E. Provide the annual reports required by the MOU.
The SPHA has sent, on an annual basis, the Report on Audit of Financial Statements to the
HUD office. In the future, we will also include a breakdown of the expenditure description,
amount and period as a separate report, if necessary.
Finding 4- THE AUTHORITY MADE INAPPROPRIATE TRANSFERS OF
PUBLIC HOUSING FUNDS USING ITS MASTER FUND.
4A. Require the Authority to reconcile the receivables and payables in the interfund
accounts, make appropriate adjustments, and then close the master fund.
This recommendation is being implemented. The SPHA is in the process of reconciling the
receivables and payables in the interfund accounts. The master fund is no longer in use and
has been replaced by a revolving fund. The SPHA has requested direct deposit of all
public housing funds into our conventional bank account and has been verbally advised by our
local HUD office that this will be effective May 1, 2000. We have contacted our bank to
remove the name ‘master fund’ from the account. In addition, SPHA is in the process of
converting to a new computer system and all accounts are in accordance with HUD
requirements and are appropriately titled.
4B. Require the Authority to establish a revolving fund accounting system to process
joint costs only. The system should have its own general ledger and be reconciled each
month.
A revolving fund has been established and is the operating account, in which each program
pays it’s respective portion of expenses. The revolving fund has a separate general ledger,
and is reconciled on a monthly basis.
4C,D. Require the Authority to make program payments from program accounts.
Obtain assurance that controls exist to ensure the Authority pays only specific program
costs from funds provided for the specific program.
The SPHA is in the process of converting to a new software program. Funds will be advanced
at the beginning of the month and will be reconciled at the end of the month for all program
costs.
4E. Require the Authority to return $410,000 to the Low Income Housing Program
from non-HUD sources.
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This has been corrected. All dollars used from public housing have been reimbursed to
public housing. The SPHA has made the transfer of the $410,000 as follows:
-Upon receipt from HUD of the approximately $300,000 for Rogall Congregate, the
funds were transferred to public housing.
-The deficit in Section 8 administrative fees ($52,839) has been transferred to public
housing.
-The SPHA has paid all PILOT due and thus have received reimbursement from the
City
Finding 5- ALTERNATIVE FUNDING SOURCES NEEDED TO CONTINUE
RECREATION PROGRAMS *
This finding has been corrected. The SPHA has paid all PILOT due to the City of St.
Petersburg and thus have received reimbursement. Funds donated have been reimbursed to
the appropriate programs and the SPHA will make payment of PILOT upon closing of the
books at our year end. In accordance with the OIG recommendation, the SPHA will continue
to seek additional funding opportunities and will assure that no restricted funds are used.
* We considered the Authority’s actions satisfactory and deleted this finding.
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Appendix D
Distribution
Executive Director, Housing Authority of St. Petersburg, Florida
Deputy Secretary, SD (Room 10100)
Chief of Staff, S (Room 10000)
Special Assistant to the Deputy Secretary for Project Management, SD (Room 10100)
Acting Assistant Secretary for Administration, S (Room 10110)
Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120)
Senior Advisor to the Secretary, Office of Public Affairs, S, (Room 10132)
Deputy Assistant Secretary of Administrative Services/Director of Executive Secretariat, AX
(Room 10139)
Director of Scheduling and Advance, AL (Room 10158)
Counselor to the Secretary, S (Room 10234)
Deputy Chief of Staff, S (Room 10226)
Deputy Chief of Staff for Operations, S (Room 10226)
Deputy Chief of Staff for Programs and Policy, S (Room 10226)
Director, Office of Special Actions, AK (Room 10226)
Deputy Assistant Secretary for Public Affairs, W (Room 10222)
Special Assistant for Inter-Faith Community Outreach, S (Room 10222)
Executive Officer for Administrative Operations and Management, S (Room 10220)
Senior Advisor to the Secretary for Pine Ridge Project, W, (Room 10216)
General Counsel, C (Room 10214)
Director, Office of Federal Housing Enterprise Oversight, O (9th Floor Mailroom)
Assistant Secretary for Housing/Federal Housing Commissioner, H (Room 9100)
Office of Policy Development and Research, R (Room 8100)
Inspector General, G (Room 8256)
Assistant Secretary for Community Planning and Development, D (Room 7100)
Assistant Deputy Secretary for Field Policy and Management, SDF (Room 7108)
Government National Mortgage Association, T (Room 6100)
Assistant Secretary for Fair Housing and Equal Opportunity, E (Room 5100)
Chief Procurement Officer, N (Room 5184)
Assistant Secretary for Public and Indian Housing, P (Room 4100)
Chief Information Officer, Q (Room 3152)
Director, Office of Departmental Equal Employment Opportunity, U (Room 5128)
Director, Office of Departmental Operations and Coordination, I (Room 2124)
Chief Financial Officer, F (Room 2202)
Director, HUD Enforcement Center, V, 1250 Maryland Avenue, SW, Suite 200
Director, Real Estate Assessment Center, X, 1280 Maryland Avenue, SW, Suite 800
Director, Office of Multifamily Assistance Restructuring, Y, 1280 Maryland Avenue, SW, Suite 4000
Deputy Chief Financial Officer for Finance, FF (Room 2202) (2)
Director, Office of Budget, FO (Room 3270)
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Distribution
Secretary's Representative, 4AS
State Coordinator, Florida State Office, 4DS
Director, Office of Public Housing, 4DPH
Director, Multifamily Division, 4HHM
Audit Liaison Officer, 3AFI
Audit Liaison Officer, Office of Public and Indian Housing, PF (Room P8202)
Departmental Audit Liaison Officer, FM (Room 2206)
Acquisitions Librarian, Library, AS (Room 8141)
Counsel to the IG, GC (Room 8260)
HUD OIG Webmanager-Electronic Format Via Notes Mail (Cliff Jones@hud.gov)
Public Affairs Officer, G (Room 8256)
Director, Housing and Community Development Issue Area, U.S. GAO, 441 G Street N.W.,
Room 2474, Washington DC 20548 ATTN: Judy England-Joseph
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs,
United States Senate, Washington DC 20510-6250
The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs,
United States Senate, Washington DC 20510-6250
The Honorable Dan Burton, Chairman, Committee on Government Reform,
United States House of Representatives, Washington DC 20515-6143
The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform,
United States House of Representatives, Washington, DC 20515-4305
Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212,
O'Neil House Office Building, Washington, DC 20515-6143
Steve Redburn, Chief, Housing Branch, Office of Management and Budget, 725 17th Street, NW,
Room 9226, New Executive Office Bldg., Washington, DC 20503
Sharon Pinkerton, Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug
Policy and Human Resources, B373 Rayburn House Office Bldg., Washington, DC 20515
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St. Petersburg Housing Authority, St. Petersburg, Florida
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-05-24.
Below is a raw (and likely hideous) rendition of the original report. (PDF)