oversight

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)

      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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                                                                                       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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Finding 1

                         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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Finding 1

                         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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                    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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Finding 1

                         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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     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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                          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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                          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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                         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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                       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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         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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                         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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                       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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                         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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                       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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      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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                         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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                       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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                         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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                       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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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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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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                                                                                                     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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                                                                                                  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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                                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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    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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          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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     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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