oversight

Cuyahoga Metropolitan HA, Title V Account, Cleveland, OH

Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-03-31.

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

                                                                   Issue Date
                                                                          March 31, 2000
                                                                   Audit Case Number
                                                                          00-CH-201-1002




TO:            Thomas S. Marshall, Director of Public Housing Hub, Cleveland,
                 Area Office
               Preston A. Pace, Jr., Director of Columbus Multifamily Hub, Ohio
                 State Office


FROM:          Dale L. Chouteau, District Inspector General for Audit, Midwest

SUBJECT:       Cuyahoga Metropolitan Housing Authority
               Title V Account
               Cleveland, Ohio

We completed an audit of the Cuyahoga Metropolitan Housing Authority’s Title V account. The
review was conducted based upon news reports that funds were inappropriately paid from the
account. The objective of our audit was to determine whether the Authority’s use of funds from the
Title V account was proper.

Based upon our review of the Housing Authority’s Title V account, we found that the Authority did
not follow HUD’s requirements, Office of Management and Budget Circular A-87, State of Ohio
law, and the Authority’s policies regarding the use of Title V funds. Between January 1, 1990 and
July 31, 1998, the Authority inappropriately used $11,267,209 in Title V funds. The inappropriate
payments included $10,735,243 in Title V funds without adequate supporting documentation and
another $531,966 for costs that were not reasonable and necessary low-income housing expenses.
The Authority’s former Chief Executive Officer and/or the former Chief Operating Officer
approved $301,357 of the $531,966 (57 percent) in unnecessary and unreasonable payments. As a
result, funds were not available for other low-income housing purposes. HUD also had no
assurance that the Housing Authority paid only reasonable and necessary low-income housing
expenses.

We also found that the Housing Authority did not follow its Annual Contributions Contract with
HUD regarding the deposit of low-income housing monies. Between January 1, 1990 and July 31,
1998, the Authority inappropriately transferred $45,292 in Low-Income Housing Program funds to
its Title V bank account. As a result, the Authority had less funds for its Low-Income Housing
Program.
Management Memorandum


Within 60 days, please provide us, for each recommendation made in this report, a status report
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 provide us copies of any
correspondence or directives issued because of the audit.

Should you or your staff have any questions, please contact me at (312)353-7832.




00-CH-201-1002                            Page ii
Executive Summary
We completed an audit of the Cuyahoga Metropolitan Housing Authority’s Title V account. The
Housing Authority’s Title V account consisted of funds from various sources such as the
Authority’s veterans housing, Section 8 Program, Low-Income Public Housing Program,
Comprehensive Improvement Assistance Program, and excess bond proceeds. The excess bond
proceeds resulted from the owners’ refinancing of Ambleside, Puritas Place, and Rock-Glen
Apartments. The audit was conducted based upon news reports that funds were inappropriately
paid from the Title V account. Our audit objective was to determine whether the Authority’s use
of funds from the account was proper.

We found that the Housing Authority did not follow HUD’s requirements, Office of Management
and Budget Circular A-87, State of Ohio law, and the Authority’s policies regarding the use of
Title V funds. Between January 1990 and July 1998, the Authority inappropriately used
$11,267,209 in Title V funds. The inappropriate payments included $10,735,243 in Title V funds
without adequate supporting documentation and another $531,966 for costs that were not
reasonable and necessary low-income housing expenses. The Authority’s former Chief Executive
Officer and/or the former Chief Operating Officer approved $301,357 of the $531,966 (57
percent) in unnecessary and unreasonable payments. As a result, funds were not available for
other low-income housing purposes. HUD also had no assurance that the Housing Authority paid
only reasonable and necessary low-income housing expenses.

We also found that the Authority did not follow its Annual Contributions Contract with HUD
regarding the deposit of low-income housing monies. Between January 1990 and July 1998, the
Housing Authority inappropriately transferred $45,292 in Low-Income Housing Program funds to
its Title V bank account. As a result, the Authority had less funds for its Low-Income Housing
Program.


                                    The Housing Authority did not follow HUD’s requirements,
 The Housing Authority              Office of Management and Budget Circular A-87, State of
 Inappropriately Used               Ohio law, and the Authority’s policies regarding the use of
 $11,267,209 In Title V             Title V funds. Between January 1, 1990 and July 31, 1998,
 Funds                              the Housing Authority inappropriately used $11,267,209 in
                                    Title V funds. The inappropriate payments included
                                    $10,735,243 in Title V funds without adequate supporting
                                    documentation and another $531,966 for costs that were not
                                    reasonable and necessary low-income housing expenses.
                                    The Housing Authority’s former Chief Executive Officer
                                    and/or the former Chief Operating Officer approved
                                    $301,357 of the $531,966 (57 percent) in unnecessary and
                                    unreasonable payments. The problems occurred because the
                                    Housing Authority’s former top management and Board of
                                    Commissioners failed to adequately exercise their duties.
                                    The Housing Authority’s former top management also
                                    circumvented the Authority’s policies.


                                         Page iii                               00-CH-201-1002
Executive Summary


                             The Housing Authority did not follow its Annual
 The Housing Authority       Contributions Contract with HUD regarding the deposit of
 Inappropriately Deposited   low-income housing monies. Between January 1, 1990 and
 $45,292 In Its Title V      July 31, 1998, the Housing Authority inappropriately
 Account                     transferred $45,292 in Low-Income Housing Program funds
                             to its Title V bank account. The problem occurred because
                             the Housing Authority’s Board of Commissioners and former
                             top management failed to establish adequate controls over
                             the deposit of low-income housing funds.

                             We recommend that HUD’s Cleveland Area Office Director
 Recommendations             of Public Housing Hub, in conjunction with HUD’s Ohio
                             State Office Director of Columbus Multifamily Hub, assures
                             that the Cuyahoga Metropolitan Housing Authority:
                             implements controls to correct the weaknesses cited in this
                             report; provides documentation to support the $10,735,243
                             of unsupported payments or reimburse its Title V account
                             from non-Federal funds for the amount that cannot be
                             adequately supported; reimburses its Title V account
                             $531,966 from non-Federal funds for the ineligible
                             payments; and transfers the $45,292 of inappropriate
                             deposits from its Title V bank account to the Low-Income
                             Housing Program General Fund.

                             We presented our draft findings to the Housing Authority’s
                             Executive Director and HUD’s staff during the audit. We
                             held an exit conference with the Housing Authority’s
                             Executive Director and the Authority’s Chairman of the
                             Board of Commissioners on March 13, 2000. The Authority
                             provided written comments to our findings. The Housing
                             Authority said it had supporting documentation for a number
                             of large disbursements; however, the Authority did not
                             provide the supporting documentation with its comments.
                             We included paraphrased excerpts of the comments with
                             each finding (see Findings 1 and 2). The complete text of
                             the comments are in Appendix B with the exception of three
                             attachments that were not necessary for understanding the
                             Authority’s comments. A complete copy of the Authority’s
                             comments with the attachments were provided to HUD’s
                             Cleveland Area Office Director of Public Housing Hub and
                             HUD’s Ohio State Office Director of Columbus Multifamily
                             Hub.




00-CH-201-1002                    Page iv
Table Of Contents

Management Memorandum                                                i


Executive Summary                                                 iii


Introduction                                                         1


Findings

1    The Housing Authority Inappropriately Used
     $11,267,209 In Title V Funds                                3


2    The Housing Authority Inappropriately Deposited
     $45,292 In Its Title V Account                                  15



Follow Up On Prior Audits                                   19


Appendices
      A Schedule Of Questioned Costs                         21

      B Auditee Comments                                     23

      C Distribution                                         27




                            Page v                     00-CH-201-1002
Table Of Contents




                    (THIS PAGE LEFT BLANK INTENTIONALLY)




00-CH-201-1002                   Page vi
Introduction
The Cuyahoga Metropolitan Housing Authority was organized under the laws of the State of Ohio
to develop, acquire, and operate low-income housing programs. A five-member Board of
Commissioners is responsible for monitoring the Housing Authority’s operations. The Chairman
of the Housing Authority’s Board is Bracey E. Lewis and the Authority’s Executive Director is
Terri Hamilton Brown. The Housing Authority’s official records are located at 2711 Church
Avenue, Cleveland, Ohio.

The Housing Authority is authorized to administer low-income housing programs throughout
Cuyahoga County, which includes the Cities of Cleveland, East Cleveland, Cleveland Heights, and
Oakwood. The Housing Authority executed cooperation agreements with these four municipalities
which provides the legal basis for the Authority’s operations.

On December 31, 1945, the Federal Government amended Title V of the Lanham Act. The Act
authorized funds to the Veterans Administration for disassembling, transporting, reerecting, and
converting surplus war structures supplied by educational institutions, State and local bodies, and
nonprofit organizations to provide housing for veterans, their families, and distressed families of
servicemen. In 1953, the Veterans Administration transferred the housing in Cuyahoga County to
the Housing Authority.

The Housing Authority sold its veterans housing in 1958 and invested the proceeds into its Title V
bank account. There was very little activity to the Authority’s Title V bank account until 1990. At
that time, the Housing Authority’s former Chief Executive Officer and the former Chief Operating
Officer paid expenses from the Title V account which HUD would not permit the Authority to pay
from Federal funds.

Between January 1990 and July 1998, the Housing Authority’s Title V account consisted of funds
from various sources such as the Authority’s veterans housing, Section 8 Program, Low-Income
Public Housing Program, Comprehensive Improvement Assistance Program, and excess bond
proceeds. The excess bond proceeds resulted from the refinancing by the owners of Ambleside,
Puritas Place, and Rock-Glen Apartments. The Housing Authority was HUD’s Section 8 contract
administrator for the three apartment projects.

HUD and the Housing Authority executed a Memorandum of Understanding in December 1994
which outlined the use of the excess bond proceeds from Ambleside Apartments. The
Memorandum of Understanding required the Authority to use the bond proceeds to construct
additional low-income housing. HUD and the Authority did not execute an agreement in relation to
the bond proceeds from Puritas Place and Rock-Glen Apartments.


                                      Our audit objective was to determine whether the
 Audit Objectives                     Authority’s use of funds from the Title V account was
                                      proper.

                                      We conducted the audit at HUD’s Cleveland Area Office,
 Audit Scope And                      the State of Ohio’s Auditor of State Office, and the Housing
 Methodology
                                           Page 1                                  00-CH-201-1002
Introduction


                 Authority. We performed our on-site audit work between
                 August 1998 and February 2000.

                 To determine whether the Housing Authority’s use of funds
                 from the Title V account was proper, we reviewed the
                 Housing Authority’s: personnel files; general ledgers; cash
                 receipts and disbursements journals; canceled checks and
                 bank statements; travel vouchers; Board meeting minutes;
                 vendor files and contracts; and payroll records. We also
                 reviewed HUD’s files and the State of Ohio’s Auditor of
                 State audit files for the Housing Authority. We interviewed:
                 HUD’s staff; State audit officials; and the Housing
                 Authority’s Commissioners and employees.

                 The audit covered the period January 1, 1990 to July 31,
                 1998. We extended our audit period as necessary. We
                 conducted our audit in accordance with generally accepted
                 government auditing standards. However, we did not assess
                 the Authority’s management controls since our review was
                 to determine whether the Authority’s use of funds from the
                 Title V account was proper, and our testing of the account
                 included 100 percent of the transactions.

                 We provided a copy of this report to the Housing Authority’s
                 Executive Director and the Chairman of the Board.




00-CH-201-1002        Page 2
                                                                                        Finding 1



    The Housing Authority Inappropriately Used
          $11,267,209 In Title V Funds
The Cuyahoga Metropolitan Housing Authority did not follow HUD’s requirements, Office of
Management and Budget Circular A-87, State of Ohio law, and the Authority’s policies regarding
the use of Title V funds. Between January 1, 1990 and July 31, 1998, the Housing Authority
inappropriately used $11,267,209 in Title V funds. The inappropriate payments included
$10,735,243 in Title V funds without adequate supporting documentation and another $531,966 for
costs that were not reasonable and necessary low-income housing expenses. The Housing
Authority’s former Chief Executive Officer and/or the former Chief Operating Officer approved
$301,357 of the $531,966 (57 percent) in unnecessary and unreasonable payments. The problems
occurred because the Housing Authority’s former top management and Board of Commissioners
failed to adequately exercise their duties. The Housing Authority’s former top management also
circumvented the Authority’s policies. As a result, funds were not available for other low-income
housing purposes. HUD also had no assurance that the Housing Authority paid only reasonable
and necessary low-income housing costs.


                                     Section 3735.37 of the Ohio Revised Code requires that a
 Veterans Housing                    metropolitan housing authority, which received as a gift from
 Projects’ Income                    the Federal government certain buildings erected as
 Requirement                         temporary homes for veterans, use the income from the
                                     housing project to eliminate slum areas, and prepare plans
                                     and construct housing for low-income families.

                                     The Consolidated Annual Contributions Contract for the
 Section 8 Program                   Section 8 Housing Certificate Program and Housing Voucher
 Requirements                        Program requires the Cuyahoga Metropolitan Housing
                                     Authority to use Program receipts to provide housing to low
                                     and moderate income families. Program receipts may only
                                     be used to pay Program expenditures.

                                     The Contract also requires the Housing Authority to maintain
                                     an Operating Reserve account consisting of the Section 8
                                     administrative fees earned and interest earned on the
                                     Operating Reserve. The Housing Authority may use the
                                     Operating Reserve funds for other housing purposes
                                     consistent with State and local law.



                                     24 CFR Part 85.20 requires the Housing Authority to
 Low-Income Public                   maintain accounting records that adequately identify the
 Housing And                         application of funds as well as expenditures. 24 CFR Part
 Comprehensive Assistance
 Grant Requirements                       Page 3                                  00-CH-201-1002
Finding 1


                             85.22(b) requires that State, local, and Indian tribal
                             governments follow Office of Management and Budget
                             Circular A-87, Cost Principles for State, Local, and Indian
                             Tribal Governments. 24 CFR Part 85.3 defines a local
                             government to include any public housing agency.

                             Office of Management and Budget Circular A-87,
                             Attachment A, paragraph C(1)(a), requires that all costs be
                             necessary and reasonable for proper and efficient
                             performance and administration of Federal awards. In
                             addition, paragraph C(1)(j) requires that all costs be
                             adequately documented. Circular A-87 applies to the Low-
                             Income Public Housing and the Comprehensive Improvement
                             Assistance Programs, not the Section 8 Program.

                             The Annual Contributions Contract, Section 401(D), says the
                             Cuyahoga Metropolitan Housing Authority may withdraw
                             monies from the Low-Income Public Housing General Fund
                             for the payment of low-income housing development costs
                             and operating expenditures.

                             HUD Handbook 7485.1 REV-4, The Public and Indian
                             Housing Comprehensive Improvement Assistance Program
                             Handbook, Chapter 1, Paragraph 1, requires housing
                             authorities to use Comprehensive Improvement Assistance
                             Program funds to improve the physical condition and
                             upgrade the management and operation of existing public
                             housing projects to assure that such projects continue to
                             provide housing to low-income families.

                             The Memorandum of Understanding dated December 28,
 Use Of Ambleside            1994, between HUD and the Cuyahoga Metropolitan
 Apartments’ Excess Bond     Housing Authority, requires the Housing Authority to use the
 Proceeds                    bond proceeds from Ambleside Apartments to construct
                             housing units for very low-income elderly, handicapped, and
                             disabled households.

                             Section 3735.37 of the Ohio Revised Code requires
 General Requirements For    metropolitan housing authorities to keep an accurate account
 Housing Authorities         of all receipts and expenditures.

                             24 CFR Part 24 allows HUD to take administrative action
                             against individuals who violate HUD’s requirements.

                             Public Housing Authority Commissioners have a
 Responsibilities Of Board   responsibility to HUD to ensure national housing policies
 Of Commissioners And
 Management Staff
00-CH-201-1002                    Page 4
                                                                             Finding 1


                           are carried out, and to the Authority’s management staff and
                           employees to provide sound and manageable directives.
                           The Commissioners are accountable to their locality and
                           best serve it by monitoring operations to be certain that
                           housing programs are carried out in an efficient and
                           economical manner.

                           The responsibility for carrying out the Commissioners'
                           policies and managing the Housing Authority's day-to-day
                           operations rests with the Authority’s principal management
                           staff. In particular, the management staff must maintain the
                           Housing Authority's overall compliance with its policies and
                           procedures and Federal, State, and local laws.

                           We reviewed 100 percent of the disbursements from the
Disbursements Reviewed     Housing Authority’s Title V account for the period between
And Schedules Provided     January 1, 1990 and July 31, 1998. We reviewed the
                           disbursements to determine whether the costs were
                           reasonable and necessary low-income housing expenses.
                           The Authority paid $16,593,565 from the Title V account for
                           the time period reviewed. The Housing Authority’s Title V
                           account consisted of funds commingled from various sources
                           such as the Authority’s veterans housing, Section 8 Program,
                           Low-Income Public Housing Program, Comprehensive
                           Improvement Assistance Program, and excess bond
                           proceeds. The excess bond proceeds resulted from the
                           owners’ refinancing of Ambleside, Puritas Place, and Rock-
                           Glen Apartments. We were unable to determine which funds
                           were used for the disbursements reviewed.

                           We determined that the Housing Authority paid unsupported
                           and ineligible costs from the Title V account. We prepared
                           schedules showing the unsupported and ineligible payments
                           and provided the schedules to HUD’s Cleveland Area
                           Office Director of Public Housing Hub, HUD’s Ohio State
                           Office Director of Columbus Multifamily Hub, and the
                           Housing Authority’s Executive Director.

                           The Cuyahoga Metropolitan Housing Authority improperly
The Authority Lacked       used $10,735,243 in Title V funds that were not adequately
Documentation To Support   supported. The payments occurred between January 1, 1990
Over $10 Million In        and July 31, 1998. HUD’s regulation, Office of Management
Payments                   and Budget Circular A-87, and State of Ohio law require
                           housing authorities to maintain records that adequately
                           identify the use of funds by the authorities. Housing



                                Page 5                                 00-CH-201-1002
Finding 1


                        authorities must ensure funds are expended for reasonable
                        and necessary low-income housing expenses.

                        In order to determine whether the Housing Authority used its
                        Title V funds properly, we reviewed such items as the
                        Authority’s general ledgers, canceled checks, and check
                        request forms. The Housing Authority lacked documentation
                        to show that Title V funds were used for other low-income
                        housing purposes or that funds were used for only
                        reasonable and necessary low-income housing expenses. A
                        Housing Authority Commissioner said the Authority’s Board
                        relied on the principal management staff to ensure funds
                        were used appropriately. He also said the Board relied on
                        the Authority’s management staff to maintain documentation
                        to support disbursements. The Authority’s former Chief
                        Executive Officer and the former Chief Operating Officer
                        were the Authority’s principal management staff. They were
                        responsible for ensuring that the Authority complied with its
                        policies and procedures and Federal, State, and local laws.
                        However, this was not done.

                        The $10,735,243 of unsupported payments represented 65
                        percent of the total funds used from the Housing Authority’s
                        Title V account between January 1990 and July 1998. Given
                        the large percentage of unsupported payments, we believe
                        the Housing Authority’s Board of Commissioners failed to
                        ensure that the Authority operated in an efficient and
                        economical manner. The following table shows the amount
                        of unsupported payments per year.




                 Year       Unsupported Payments
                 1990           $ 219,155
                 1991             3,267,674
                 1992             1,956,832
                 1993             1,325,416
                 1994               453,253
                 1995             3,218,742
                 1996               147,991
                 1997               141,939
                 1998                 4,241

00-CH-201-1002               Page 6
                                                                                      Finding 1

                            Total            $10,735,243


                                    As a result, HUD had no assurance that the Housing
                                    Authority paid only reasonable and necessary low-income
                                    housing costs.

                                    The Housing Authority paid $531,966 of Title V funds for
The Authority                       costs that were not reasonable and necessary low-income
Inappropriately Used                housing expenses, did not provide for additional low-
$531,966 In Title V Funds           income housing, and violated the Authority’s policies. The
                                    expenses included: (1) $109,873 for payments on the former
                                    Chief Executive Officer’s townhouse; (2) $53,571 for meals
                                    at local restaurants; (3) $195,127 in payments to the former
                                    Chief Operating Officer for monetized vacation time,
                                    compensatory time, and the cost of the Operating Officer’s
                                    additional life and disability insurance; (4) $164,001 for
                                    political and charitable contributions; and (5) $9,394 for
                                    flowers. The payments occurred between January 1990 and
                                    July 1998.

                                    The Housing Authority inappropriately used Title V funds
Funds Were Used To Pay              for payments toward the former Chief Executive Officer’s
For The Former Chief                townhouse in Alexandria, Virginia. The former Chief
Executive Officer’s                 Executive Officer claimed the townhouse payments were
Townhouse                           approved by three of the Housing Authority’s
                                    Commissioners. She also claimed the payments were part of
                                    her relocation package when she was hired by the Authority.

                                    The three Commissioners denied ever approving the
                                    townhouse payments. The townhouse payments were not
                                    included in the former Chief Executive Officer’s contract
                                    with the Authority. Resolution 188-90, adopted by the
                                    Housing Authority effective October 3, 1990, required the
                                    Authority’s employees to follow the Federal Government’s
                                    travel regulations. Federal travel regulations prohibit
                                    reimbursement of relocation expenses after two years from
                                    the date the employee reports to the new duty station.
                                    However, the townhouse payments started after the former
                                    Chief Executive Officer was employed with the Housing
                                    Authority for over two years. Therefore, the townhouse
                                    payments violated the Authority’s travel policy. The
                                    payment of these expenses also prevented funds from being
                                    spent for other low-income housing purposes.

                                    The Authority inappropriately paid $53,571 in Title V funds
The Authority Used Title            for meals at restaurants located in the Cleveland, Ohio
V Funds To Pay For Meals
At Local Restaurants                     Page 7                                 00-CH-201-1002
Finding 1


                            metropolitan area. The meal expenses violated Office of
                            Management and Budget Circular A-87 because the
                            expenses were not reasonable and necessary low-income
                            housing costs. The payment of these expenses also
                            prevented funds from being spent for other low-income
                            housing purposes as required by HUD’s Section 8 Annual
                            Contributions Contract, the Memorandum of Understanding
                            with HUD, and State of Ohio law. The Authority lacked
                            documentation to show the meal expenses were associated
                            with legitimate low-income housing purposes.

                            The Authority paid $155,546 in Title V funds to the former
 Title V Funds Were         Chief Operating Officer for monetized vacation and
 Inappropriately Used To    compensatory time. The Authority also used $39,581 in
 Benefit The Former Chief   Title V funds to pay for additional life and disability
 Operating Officer          insurance coverage for the former Chief Operating Officer.
                            The payments of the monetized vacation time, compensatory
                            time, and insurance coverage were not reasonable and
                            necessary low-income housing expenses, and were not
                            available to be used for other low-income housing purposes
                            as required by State of Ohio law, HUD’s Section 8 Annual
                            Contributions Contract, and the Memorandum of
                            Understanding with HUD. The payments also did not follow
                            the Authority’s policies.

                            Page 15 of the Personnel Policy adopted by the Housing
                            Authority on October 6, 1993, says all personnel employed
                            by the Authority who occupy positions which are exempt
                            from the Fair Labor Standards Act of 1938 and are not
                            subject to a collective bargaining agreement are not entitled
                            to the payment of overtime or compensatory time. The
                            Authority’s Management Bulletin 13-91, dated November 8,
                            1991, showed that the former Chief Operating Officer was
                            exempt from the Fair Labor Standards Act. The Authority’s
                            Personnel Policy also did not permit employees to monetize
                            their vacation. However, the Authority routinely paid the
                            former Chief Operating Officer for monetized vacation time
                            and compensatory time.             The Authority lacked
                            documentation showing the compensatory time worked by
                            the former Chief Operating Officer.

                            Title V funds were used to pay the former Chief Operating
                            Officer’s disability and additional life insurance, making
                            these funds unavailable for other low-income housing
                            purposes. Based upon Office of Management and Budget
                            Circular A-87, the payment of the insurance expense was not

00-CH-201-1002                   Page 8
                                                                                Finding 1


                            a reasonable and necessary low-income housing cost. The
                            payment of the former Chief Operating Officer’s insurance
                            expense was also not permitted by the Authority’s policies.
                            Page 12 of the Authority’s Personnel Policy says all regular
                            full-time employees and their legal dependents will be
                            eligible for group health, dental, prescription drug, and
                            vision coverage 120 days after employment. The Personnel
                            Policy says all regular full-time employees will be eligible
                            for basic life insurance coverage. The Personnel Policy
                            does not provide for the payment of an employee’s
                            additional life or disability insurance by the Authority.

                            The Housing Authority inappropriately used $164,001 in
The Authority Used Title    Title V funds to make political and charitable contributions,
V Funds To Pay Political    and an additional $9,394 in Title V funds were used for
Contributions, Charitable   floral expenses. The charitable and political expenses
Donations, And Flowers      included such items as luncheons benefiting local non-profit
                            groups and advertisements endorsing a local political
                            official. The political, charitable, and floral expenses
                            violated State of Ohio law, HUD’s Section 8 and Low-
                            Income Housing Annual Contributions Contracts, and the
                            Memorandum of Understanding with HUD. The expenses
                            were not reasonable and necessary low-income housing
                            costs, and precluded their use for other low-income housing
                            purposes as required by HUD’s requirements and State law.



                            The Housing Authority’s former Chief Executive Officer
The Authority’s Former      and/or the former Chief Operating Officer approved
Management Approved         $301,357 of the $531,966 (57 percent) in unnecessary and
The Ineligible Expenses     unreasonable payments. The former Chief Executive Officer
                            and the former Chief Operating Officer were the Authority’s
                            principal management. As such, they were responsible for
                            ensuring the Housing Authority’s overall compliance with its
                            policies and procedures and Federal, State, and local laws.

                            HUD suspended the Authority’s former Chief Executive
                            Officer from participating in HUD’s programs in 1998.
                            Based upon this and the failure of the former Chief
                            Executive Officer to ensure that Title V funds were used
                            appropriately, we believe that HUD should debar the former
                            Chief Executive Officer from participating in any Federal
                            programs. The Authority’s former Chief Operating Officer
                            is currently the Executive Director of the San Francisco
                            Housing Authority. In this capacity, he controls a substantial

                                 Page 9                                   00-CH-201-1002
Finding 1


                    portion of HUD funds. We believe that HUD should pursue
                    the strongest administrative action against the Authority’s
                    former Chief Operating Officer based upon the information
                    contained in this finding and HUD’s exposure to additional
                    loss of funds given the former Chief Operating Officer’s
                    current employment.


 Auditee Comments   [Excerpts paraphrased from the Executive Director’s
                    comments on our draft finding follow. Appendix B, pages
                    23 to 26, contains the complete text of the comments.]

                    Review of Unsupported Payments

                    Of the total 1,708 payments questioned, the Housing
                    Authority initially reviewed a sample of 25 totaling
                    $2,284,043 to determine if there was any documentation to
                    support the payments. Our review discovered:

                    1.     Ten of the 25 (40 percent) payments were supported
                           with proper documentation and approval signatures.
                           Two of the expenditures were wire transfers for
                           $1,000,000 each to the Section 8 and Low-Income
                           Public Housing bank accounts. The transfers were
                           made to cover Housing Assistance Payments to
                           Section 8 landlords and operating expenses for the
                           Low-Income Public Housing Program because the
                           HUD subsidy payments to the Authority were late;
                           and

                    2.     Fifteen of the 25 (60 percent) voucher packages
                           could not be located. However, three of the voucher
                           packages were never returned from the HUD
                           auditors and one from the Executive Office (prior
                           administration).

                    Upon completing the review of the initial sample of 25
                    payments, the Housing Authority proceeded to select 34
                    debit memos and wire transfers totaling $9,021,727
                    (accounting for approximately 84 percent of the total
                    questioned costs). From the second sample, the review
                    concluded that:

                    1.     Four payments totaling approximately $3.6 million
                           were made to ensure funds were available to cover
                           Section 8 Housing Assistance Payments and Low-

00-CH-201-1002           Page 10
                                                                      Finding 1


                           Income Public Housing expenses when the HUD
                           subsidy to the Authority was late. In each instance,
                           funds were transferred back to the Title V account
                           upon receipt of the HUD subsidy;

                    2.     Supporting documentation was identified for nine
                           payments totaling $414,675; and

                    3.     Combining items #1 and #2, approximately 13 of the
                           34 (38 percent) payments were supported with
                           documentation.

                    Based on the two samples researched by the Housing
                    Authority, the Authority respectfully submits the additional
                    documentation for consideration.

OIG Evaluation Of   The Housing Authority did not provide adequate supporting
Auditee Comments    documentation with its comments. The Authority submitted
                    two spreadsheets showing the date of the payments sampled,
                    the payment amount, the vendor’s name, and a description of
                    the payment. The Authority needs to provide HUD
                    documentation to support the $10,735,243 of unsupported
                    payments cited in this finding. If documentation cannot be
                    provided, then the Housing Authority should reimburse its
                    Title V account from non-Federal funds for the amount that
                    cannot be adequately supported.

                    We returned all of the Housing Authority’s records at the
                    conclusion of our review.


Auditee Comments    Review of Unnecessary and Unreasonable Payments

                    The Housing Authority is presently reviewing the costs cited
                    in the audit in relation to State laws and the Authority’s
                    requirements. In the past, the Authority used the Title V
                    account to fund costs that may not be eligible for Federal
                    funding.

                    The Housing Authority was awarded a judgment to recapture
                    the [townhouse] payments related to the former Chief
                    Executive Officer.

OIG Evaluation Of   The Housing Authority used Title V funds for costs that were
Auditee Comments    not reasonable and necessary low-income housing expenses,
                    were not available for other low-income housing purposes,

                         Page 11                                00-CH-201-1002
Finding 1


                     and violated the Authority’s policies. The expenses
                     included: payments on the former Chief Executive Officer’s
                     townhouse; meals at local restaurants; payments to the
                     former Chief Operating Officer for monetized vacation time,
                     compensatory time, and the cost of the Operating Officer’s
                     additional life and disability insurance; political and
                     charitable contributions; and flower expenses.

                     The Housing Authority should reimburse its Title V account
                     from non-Federal funds for the ineligible payments. If the
                     Authority receives funds from the judgment against the
                     former Chief Executive Officer, those funds should be
                     deposited to the Title V account.


 Auditee Comments    Of more importance to note are the reforms and procedures
                     that the Housing Authority’s Board and current
                     administration have implemented to restore fiscal soundness,
                     adherence to policy, and program compliance within the
                     Authority. The most significant controls achieved to date
                     include:

                     •   Restructuring the Authority’s Internal Audit Department
                         function and reporting structure, and establishing an
                         external Audit Committee to the Authority’s Board of
                         Commissioners;

                     •   Restructuring the Authority’s Financial Services
                         Department organizational structure, hiring a new Chief
                         Financial Officer, and closely monitoring the operations
                         of the budget and accounting sections; and

                     •   Completing the 1997 and 1998 financial audits, and
                         preparing corrective action plans to address all findings.

                     The full attention and effort of the Housing Authority’s
                     Board and current administration is to establish and maintain
                     appropriate controls and accountability expected of an
                     agency that receives public funds.

 OIG Evaluation Of   Based upon the actions taken or planned, the Housing
 Auditee Comments    Authority will improve its controls over disbursements, if
                     the procedures are fully implemented. Disbursements from
                     the Authority’s Title V account should meet HUD’s
                     requirements, the Office of Management and Budget Circular


00-CH-201-1002            Page 12
                                                                       Finding 1


                  A-87, the State of Ohio’s Revised Code, and the Authority’s
                  policies.


Recommendations   We recommend that the Cleveland Area Office Director of
                  Public Housing Hub, in conjunction with the Ohio State
                  Office Director of Columbus Multifamily Hub, assures that
                  the Cuyahoga Metropolitan Housing Authority:

                  1A.         Provides documentation to support the
                          $10,735,243 of unsupported payments cited in this
                          finding. If documentation cannot be provided, then
                          the Housing Authority should reimburse its Title V
                          account from non-Federal funds for the amount that
                          cannot be adequately supported.

                  1B.     Reimburses its Title V account $531,966 from non-
                          Federal funds for the ineligible payments cited in this
                          finding.


                  1C.     Establishes procedures and controls to ensure that
                          disbursements from the Title V account meet HUD’s
                          requirements, the Office of Management and Budget
                          Circular A-87, the State of Ohio’s Revised Code,
                          and the Authority’s policies.

                  We also recommend that the Cleveland Area Office Director
                  of Public Housing Hub, in conjunction with the Ohio State
                  Office Director of Columbus Multifamily Hub:

                  1D.     Initiates debarment action against the former Chief
                          Executive Officer as authorized by 24 CFR Part 24.

                  1E.     Takes administrative action against the former Chief
                          Operating Officer as authorized by 24 CFR Part 24.




                        Page 13                                  00-CH-201-1002
Finding 2



        The Housing Authority Inappropriately
       Deposited $45,292 In Its Title V Account
The Cuyahoga Metropolitan Housing Authority did not follow its Annual Contributions Contract
with HUD regarding the deposit of low-income housing monies. Between January 1, 1990 and
July 31, 1998, the Housing Authority inappropriately transferred $45,292 in Low-Income Housing
Program funds to its Title V bank account. The problem occurred because the Housing Authority’s
Board of Commissioners and former top management failed to establish adequate controls over the
deposit of low-income housing funds. As a result, the Authority had less funds for its Low-Income
Housing Program.


                                     The Annual Contributions Contract, Section 401(B), says all
 Annual Contributions                monies received by the Cuyahoga Metropolitan Housing
 Contract                            Authority in connection with the Projects shall constitute the
                                     General Fund. Section 401(C) of the Contract requires the
                                     Housing Authority to deposit promptly all monies
                                     constituting the General Fund with such bank or banks per
                                     the terms of the General Depository Agreement.

                                     Public Housing Authority Commissioners have a
 Responsibilities Of Board           responsibility to HUD to ensure national housing policies
 Of Commissioners And                are carried out, and to the Authority’s management staff and
 Management Staff                    employees to provide sound and manageable directives.
                                     The Commissioners are accountable to their locality and
                                     best serve it by monitoring operations to be certain that
                                     housing programs are carried out in an efficient and
                                     economical manner.

                                     The responsibility for carrying out the Commissioners'
                                     policies and managing the Housing Authority's day-to-day
                                     operations rests with the Authority’s principal management
                                     staff. In particular, the management staff must maintain the
                                     Housing Authority's overall compliance with its policies and
                                     procedures and Federal, State, and local laws.

                                     We reviewed 100 percent of the monies deposited into the
Deposits Reviewed And                Housing Authority’s Title V bank account for the period
Schedule Provided                    between January 1, 1990 and July 31, 1998. We reviewed
                                     the transactions to determine whether the Housing Authority
                                     appropriately deposited funds to its Title V account. The
                                     Authority deposited $16,036,057 to its Title V account for
                                     the time period reviewed. As of February 29, 2000, the
                                     Housing Authority had $282,981 in its Title V bank account.

00-CH-201-1002                            Page 14
                                                                                  Finding 2



                               During our review, we determined that the Housing
                               Authority inappropriately deposited monies to the Title V
                               account. The Authority was required to deposit the monies
                               to its Low-Income Housing Program General Fund bank
                               account.     A schedule was prepared showing the
                               inappropriate deposits. We provided the schedule to HUD’s
                               Cleveland Area Office Director of Public Housing Hub and
                               the Housing Authority’s Executive Director.

                               The     Cuyahoga      Metropolitan   Housing     Authority
The Authority Improperly       inappropriately deposited $45,292 in low-income housing
Transferred $45,292 To         funds to its Title V bank account. The deposits occurred
Its Title V Account            between January 1, 1990 and July 31, 1998. The Annual
                               Contributions Contract between the Housing Authority and
                               HUD required the Authority to deposit all proceeds from its
                               Projects to the Low-Income Housing Program General Fund.
                               However, this was not always done.

                               The following table shows the amount of funds
                               inappropriately deposited to the Housing Authority’s Title V
                               bank account per year.

                           Year      Diverted Deposits
                           1990          $    509
                           1991             9,590
                           1992                 0
                           1993            10,000
                           1994                 0
                           1995                 0
                           1996                 0
                           1997            21,193
                           1998             4,000
                           Total         $45,292

                               The $45,292 of inappropriate deposits to the Housing
                               Authority’s Title V bank account included: (1) $24,000 of
                               rental payments from AT&T; (2) $10,000 in legal
                               settlements; (3) $5,783 in insurance claims or refunds; (4)
                               $5,000 for contractor default fees; and (5) $509 in laundry
                               and vending machine income.

                               For example, the $24,000 in deposits from AT&T were for
                               rental payments for satellite dishes installed on the Housing
                               Authority’s low-income housing high rise Projects. The

                                    Page 15                                 00-CH-201-1002
Finding 2


                     Housing Authority made the deposits in 1997 and 1998. The
                     Annual Contributions Contract required the Housing
                     Authority to deposit monies received from its Projects to the
                     Low-Income Housing Program General Fund.

                     The problem occurred because the Housing Authority’s
                     Board of Commissioners and former top management did not
                     establish adequate controls over the deposit of low-income
                     housing funds. A Housing Authority Commissioner said the
                     Authority’s Board relied on the principal management staff
                     to ensure funds were accounted for properly. He also said
                     the Board relied on the Authority’s management staff to
                     administer the Housing Authority in accordance with all
                     applicable requirements. The Authority’s former Chief
                     Executive Officer and the former Chief Operating Officer
                     were the Authority’s principal management staff. They were
                     responsible for ensuring that the Authority complied with the
                     Annual Contributions Contract. As a result, the Housing
                     Authority had less funds for its Low-Income Housing
                     Program.


 Auditee Comments    [Excerpts paraphrased from the Executive Director’s
                     comments on our draft finding follow. Appendix B, pages
                     23 to 26, contains the complete text of the comments.]

                     Review of Inappropriate Deposits

                     All regular activity with the Title V account was suspended
                     in 1998 and the last transaction was recorded in April 1999.
                     All funds deemed to be inappropriately deposited will be
                     returned to the Authority’s General Fund for the Low-Income
                     Housing Program. The Authority’s Internal Audit and Legal
                     Departments are reviewing the Annual Contributions
                     Contract related to this finding.

 OIG Evaluation Of   The proposed action by the Housing Authority to return the
 Auditee Comments    funds inappropriately transferred from the Low-Income
                     Public Housing General Fund should resolve this finding.
                     However, the Authority should establish procedures and
                     controls to ensure that the applicable program funds are
                     deposited to the appropriate account in the future.




00-CH-201-1002            Page 16
                                                                      Finding 2


Recommendations   We recommend that the Director of Public Housing Hub,
                  Cleveland Area Office, assures that the Cuyahoga
                  Metropolitan Housing Authority:

                  2A.         Transfers the $45,292 of inappropriate deposits
                          cited in this finding from its Title V bank account to
                          the Low-Income Housing Program General Fund.

                  2B.     Establishes procedures and controls to ensure that
                          the applicable program funds are deposited to the
                          appropriate account.




                        Page 17                                 00-CH-201-1002
Follow Up On Prior Audits
This is the first audit of the Cuyahoga Metropolitan Housing Authority’s Title V account by HUD’s
Office of Inspector General. The latest single audit for the Authority covered the fiscal year ended
December 31, 1998. The report contained 29 findings. Two of the 29 findings are repeated in this
report.


               Single Audit Report                           This Report

           Control and Financial Reporting        The Housing Inappropriately Used
           Environments (Finding 98-1) and $11,267,209 in Title V Funds
           Compliance with the Memorandum of      (Finding 1).
           Agreement and Allowable Costs
           (Finding 98-2).




                                           Page 19                                  00-CH-201-1002
Follow Up On Prior Audits




                      (THIS PAGE LEFT BLANK INTENTIONALLY)




00-CH-201-1002                     Page 20
                                                                             Appendix A

Schedule Of Questioned Costs


      Recommendation                Type of Questioned Costs
          Number                 Ineligible 1/    Unsupported 2/

             1A                                    $10,735,243
             1B                 $531,966
             2A                   45,292
            Total               $577,258           $10,735,243


1/    Ineligible costs are questioned costs to a HUD program or activity that the auditor
      believes are not allowable by law, contract, or Federal, State, or local policies or
      regulations.

2/    Unsupported costs are costs charged to a HUD program or activity and eligibility
      cannot be determined at the time of the audit. The costs are not supported by
      adequate documentation or there is a need for a legal or administrative
      determination on the eligibility of the cost. Unsupported costs require future
      decision by HUD program officials. This decision, in addition to obtaining
      supporting documentation, might involve a legal interpretation or clarification of
      Departmental policies and procedures.




                                  Page 21                                 00-CH-201-1002
Appendix A




                 (THIS PAGE LEFT BLANK INTENTIONALLY)




00-CH-201-1002                Page 22
                                                                                           Appendix B

Auditee Comments
March 20, 2000



Mr. Heath Wolfe
Assistant District Inspector General
 for Audit, Midwest
U.S. Department of HUD
Ralph H. Metcalfe Federal Building
77 West Jackson Boulevard, Suite 2646
Chicago, Illinois 60604-3507

Dear Mr. Wolfe:

This letter is in response to the draft audit findings of the Office of Inspector General for Audit,
HUD dated February 23, 2000 and March 8, 2000. Given the comprehensive scope of the
investigation that includes the time between January 1, 1990 and July 31, 1998; and the large
number of transactions reviewed and cited, the Cuyahoga Metropolitan Housing Authority
(CMHA) staff was not able to research each item in the amount of time provided to submit this
reply. In compliance, however, with your request, and without in any way waiving any rights
herein, we are providing this response and specifically reserve the right to provide additional
documentation for consideration as it becomes available.

CMHA’s responses are organized to address the three principle areas cited in the draft audits:

        $ 10,735,243 in Title V funds (were made) without adequate supporting
        documentation;

        $ 531,966 in Title V funds (were made for) costs that were not reasonable and
        necessary to the Authority’s operations; and

        $ 45,292 (was) inappropriately diverted (from) Low-Income Housing Program
        funds to its Title V bank account.

Staff from CMHA’s Internal Audit and Financial Services Departments were assigned to review
the payments noted in the draft audits. The results of our review are summarized in this document
(and copies of internal memos are attached for your review).


        Review of Unsupported Payments

        Of the total 1,708 items questioned, we initially reviewed a sample of 25 items
        totaling $2,284,042.72 to determine if there was any documentation to support the
        payments that were made and thus eliminate findings. Our review discovered:


                                            Page 23                                    00-CH-201-1002
Appendix B


           1. 40% or 10 of 25 payments were supported with proper documentation and
              approval signatures. It is noted that two of these expenditures were wire
              transfers in the amount of $1,000,000 each relating to Section 8 and Low
              Income Public Housing bank accounts. It appears that these transfers were
              made to cover Housing Assistance Payments to the Section 8 landlords and
              operating expenses for LIPH because the HUD subsidy payments to the
              Authority were late.

           2. 60% or 15 of 25 voucher packages could not be located. However, it
              should be noted that three of the vouchers packages were never returned
              from the HUD auditors and one from the Executive Office (prior
              administration).

Upon completing the review of the initial sample of 25 payments, the Agency proceeded to select
for review 34 debit memos and wire transfers totaling $9,021,727.41 (accounting for
approximately 84% of the total questioned costs). Of the second sample, our review concluded:

           1. Four (4) payments totaling approximately $3.6 million were made to ensure
              funds were available to cover Section 8 Housing Assistance Payments and
              Low Income Public Housing expenses when the HUD subsidy to the Agency
              was late. In each of these instances, funds were transferred back into the
              Title V account upon receipt of the HUD subsidy payments.

           2. Supporting documentation was identified for nine (9) payments totaling
              $414,674.53.

           3. Combining items #1 and #2 above, approximately 38% or 13 of 34
              payments were determined to be supported with documentation.

Based on the two samples of payments researched by CMHA staff, the Agency respectfully
submits the additional documentation for consideration and questions why these transactions were
cited. If provided a longer period of time to respond to the draft audit, it is possible to conclude
additional documentation could be identified from Agency records.

       Review of Unnecessary and Unreasonable Payments

The Board and its legal counsel have pursued and been awarded a judgment to recapture
the payments cited related to the former Chief Executive Officer.

We are presently reviewing the other costs cited in this section of the audit in relation to
State laws and the CMHA Charter and administrative policies. In the past, the Agency
used the Title V account to fund costs that may not be eligible for federal funding purposes.

       Review of Inappropriate Deposits

       All regular activity with the Title V account was suspended in 1998 and the last

00-CH-255-1002                              Page 24
                                                                                        Appendix B


       transaction was recorded in April 1999. As of today there is an account balance of
       $282,981. All funds deemed to be inappropriately deposited (in violation of the
       Annual Contribution Contract (ACC)) will be returned to the Agency’s general fund
       for Low-Income Housing Programs. The Internal Audit and Legal Departments are
       reviewing the ACC related to this finding.

At the core of the three principle findings cited in the draft audit are issues of overall lack of
adequate controls, inconsistency in accounting for expenditures and failure to comply with
applicable regulations during the administration of the former Chief Executive Officer. In
preparing this response to the draft audit, we have been able to identify some documentation not
previously reviewed by your auditors and request modification of the audit.

Of more importance to note in this response are the reforms and procedures the CMHA Board and
current administration have implemented to restore fiscal soundness, adherence to policy, and
program compliance within the Agency.

The most significant controls achieved to date include:

               Restructuring the Internal Audit Department’s function and reporting structure and
               establishing an external Audit Committee of the Board of Commissioners.
               (Attached is a comparative analysis of our audit structure to other government and
               non-profit agencies.)

               Restructuring the Financial Services Department’s organizational structure, hiring a
               new Chief Financial Officer, and closely monitoring the operations of the budget
               and accounting sections.

               Completing the 1997 and 1998 external financial audits and preparing corrective
               action plans to address all findings.

There is no doubt the full attention and effort of the CMHA Board and current administration is to
put in place and maintain appropriate controls and accountability expected of an agency that
receives public funds. We are all committed to that end and to providing quality public housing
within Cuyahoga County.

In concluding this response to the draft audit of the Title V account, CMHA pledges to continue to
fully cooperate with the Office of the Inspector General, HUD and to provide additional
documentation and responses as appropriate in the future.


Sincerely,



Terri Hamilton Brown
Executive Director

                                            Page 25                                  00-CH-201-1002
Appendix B



THB/dar

Attachments

cc: Bracy Lewis, Board Chairperson




00-CH-255-1002                       Page 26
                                                                          Appendix C

Distribution
Secretary's Representative, Midwest (2)
Senior Community Builder/State Coordinator, Cincinnati Area Office
Senior Community Builder, Cleveland Area Office
Director of Public Housing Hub, Cleveland Area Office (2)
Director of Columbus Multifamily Hub, Ohio State Office (2)
Deputy Secretary, SD (Room 10100)
Chief of Staff, S (Room 10000)
Special Assistant to the Deputy Secretary for Project Management, SD (Room 10100)
Assistant Secretary for Administration, A (Room 10110)
Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120)
Senior Advisor to the Secretary, Office of Public Affairs, W (Room 10132)
Director of Scheduling and Advance, AL (Room 10158)
Counselor to the Secretary, S (Room 10218)
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)
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 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)
Assistant Secretary for Community Planning and Development, D (Room 7100)
Executive Vice President, 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 8206)
Director of Departmental Operations and Coordination, I (Room 2124)
Chief Financial Officer, F (Room 2202)
Deputy Chief Financial Officer for Finance, FF (Room 2202)
Director of Enforcement Center, V (200 Portals Building)
Director of Real Estate Assessment Center, V (1280 Maryland Avenue, SW, Suite 800)
Director of Multifamily Assistance Restructuring, Y (4000 Portals Building)
Assistant Deputy Secretary for Field Policy and Management, SDF (Room 7108) (2)
Director of Budget, FO (Room 3270)
Internal Control and Audit Resolution Officer, 3AFI (2)
Audit Liaison Officer, PC (Room 5156) (3)
Audit Liaison Officer, HF (Room 6232) (3)
Departmental Audit Liaison Officer, FM (Room 2206) (2)
Acquisitions Librarian, Library, AS (Room 8141)
Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human
    Resources, B 373 Rayburn House Office Building, Washington DC 20515

                                     Page 27                           00-CH-201-1002
Appendix C


The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, 340
   Dirksen Senate Office Building, United States Senate, Washington DC 20510
The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs,
   706 Hart Senate Office Building, United States Senate, Washington DC 20510
Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn
   Building, United States House of Representatives, Washington DC 20515
Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204 Rayburn
   Building, United States House of Representatives, Washington DC 20515
Ms. Cindy Foglemen, Subcommittee on Oversight and Investigations, Room 212, O'Neil
   House Office Building, Washington DC 20515
Director, Housing and Community Development Issue Area, United States General
   Accounting Office, 441 G Street, N.W., Room 2474, Washington DC 20548 (Attention:
   Judy England-Joseph)
Steve Redburn, Chief, Housing Branch, Office of Management and Budget, 725 17th Street,
   N.W., Room 9226, New Executive Office Building, Washington DC 20503
Executive Director, Cuyahoga Metropolitan Housing Authority
Chairman of the Board of Commissioners, Cuyahoga Metropolitan Housing Authority




00-CH-255-1002                        Page 28