Audit Report
District Inspector General for Audit
Rocky Mountain District
Chippewa Cree Housing
Authority
Rocky Boy Reservation, Montana
Review of Housing Activities
and Related Management
Controls
00-DE-207-1004
September 21, 2000
Department of Housing and Urban Development
District Office of Inspector general For Audit
633 17th Street
14th Floor
Denver, CO 80202-3607
Audit Report
District Inspector General for Audit
Rocky Mountain District
Report: 00-DE-207-1004 Issued: September 21, 2000
TO: Michael Boyd, Acting Administrator, Northern Plains Office of Native American Programs, 8API
FROM: Robert C. Gwin, District Inspector General for Audit, 8AGA
SUBJECT: Review of Housing Activities and Related Management Controls
Chippewa Cree Housing Authority
Rocky Boy Reservation
We have completed a review of the Chippewa Cree Housing Authority’s (Authority) administration of its
HUD funded housing programs. We performed the review based upon your staff’s concerns and related
audit request. The objectives of the audit were to evaluate the:
• Housing Authority’s expenditure of funds for two log homes and management’s involvement in
developing these log homes;
• Management controls related to the operations of the Housing Authority and identify any deficiencies
or potential problem areas in the controls; and
• Determine if there were questionable, unsupported, or inappropriate transactions.
Subsequent to the completion of our field work, the HUD Northern Plains Office of Native American
Programs conducted a monitoring review of selected activities of the Authority and issued their February
20, 2000 Final Monitoring Review Report and High Risk Designation for the Indian Housing Block Grant.
Our review identified basically the same conditions that was identified and presented in HUD’s report.
The Authority’s management control structure over its various housing operations is deficient and needs to
be established and/or strengthened. Our audit report augments HUD’s review report.
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Within 60 days please furnish to this office, for each recommendation contained in the finding in this
report, a status report on: (1) the corrective action, (2) the proposed corrective action and the corrective
date to be completed, or (3) why action is considered unnecessary. Also, please furnish us copies of any
correspondence or directives issued because of the audit.
We appreciate the courtesies and assistance extended by the management and staff of the Chippewa
Cree Housing Authority, its fee accountants, RAM Enterprises, and the HUD Northern Plains Office of
Native American Programs.
Should you have any questions, please contact me, at (303) 672-5452.
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Executive Summary
We have completed a review of the Chippewa Cree Housing Authority’s administration of its HUD
housing programs. We performed the review based upon your staff’s concerns and related audit request.
Our review identified basically the same conditions that have been presented in reports issued by both
HUD and the Authority’s independent public accountant reports. We identified that the Authority’s
management control structure over its various housing operations are deficient and need to be established
and/or strengthened. One main management area related to the use of HUD program monies to fund a
non-HUD housing program. In addition, we identified deficient management controls over travel,
occupancy and leasing, and cash receipts. Without proper management controls, the Authority has limited
assurances that its housing program is being conducted in conformity with Authority’s and/or HUD’s
requirements.
Various policies and procedures have been established purportedly by the Authority’s Board of
Commissioners. The management procedures implemented by the Authority has been insufficient to
ensure that the requirements and provisions specified by the Board are being fully implemented by the
Authority staff. Also, the management controls have been deficient to provide the Authority with
reasonable assurances that its HUD program monies have been used for eligible and supported program
activities and related costs.
During our review period, the Authority changed policies and procedures based upon discussions by the
Board of Commissioners even though formal policy changes were not officially adopted by the Board.
The impact is that such policies and procedures being followed by the Authority staff may not be in full
harmony with the directives of the Board. Also, without formally adopted policies and procedures, the
Authority staff is handicapped in fully identifying and implementing the Board’s authorized directives, that
can be subject to misinterpretation and inconsistencies.
We are recommending that the Authority Board take action to ensure that all its intended policies and
procedures have been properly adopted and that such actions are fully communicated to the Authority
staff. In addition, the Authority needs to establish and implement adequate administrative and
management controls and procedures to fully implement the directives of the Board. This would include
the proper separation of duties among the Authority staff to segregate the functions of handling Authority
assets from the functions of recording Authority transactions on the Authority’s accounting records. At
the time of our review, all key functions of handling cash receipts were vested in the same Authority
employee. This same employee also controlled the main functions of verifying tenant income, establishing
tenant monthly charges, recording and maintaining tenant records and collecting delinquent amounts.
HUD’s Annual Contributions Contracts with the Authority required the
Authority must comply
Authority to carry out its HUD-funded housing programs in an economic
with HUD requirements
and efficient manner, only fund HUD authorized activities, and comply
with the various requirements specified by HUD. Title 24 of the Code of
Federal Regulations, Part 85, requires the Authority to maintain adequate
accounting records, have effective control and accountability, and have
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proper supporting documentation for its housing activities and related
costs.
During the audit period, the HUD funding for Authority housing programs
was changed to funding under the Indian Housing Block Grant program
as authorized by the Native American Housing Assistance and Self
Determination Act. Under this program the Authority is to adopt and
follow various policies and procedures governing the administration of its
HUD funded housing program. The Authority certifies to HUD that such
policies and procedures have been adopted and they are being followed
by the Authority. Also, certain provisions of Title 24, Section 85.20 of the
Code of Federal Regulations apply.
The objectives of the audit were to evaluate the:
Audit objectives
• Housing Authority’s expenditure of funds for two log homes and
management’s involvement in developing these log homes;
• Management controls related to the operations of the Housing
Authority and identify any deficiencies or potential problem areas in
the controls; and
• Determine if there were questionable, unsupported, or inappropriate
transactions.
HUD monies used to Contrary to the provisions of the Annual Contributions Contracts, the
fund $126,679 of Authority used HUD program funds totaling $126,679 to finance their
Authority’s non-HUD separate non-HUD funded housing acquisition program. The Authority’s
housing acquisition acquisition program was designed to help persons acquire homes. The
program monies were used in an attempt to acquire two log homes intended for
the former Authority Board Chairman and his brother. In addition, the
Authority has incurred legal costs totaling at $24,014 in resolving a
contract dispute related to one of the log homes.
We found during the audit period, the Authority failed to implement and
Authority lacked proper
exercise adequate controls over its travel related activities and
accountability and
expenditures. As a result, excessive, unsupported and/or questionable
controls over its travel
costs were charged to the HUD-funded housing programs. Any intended
controls were negated or minimized. More specifically, the Authority
lacked adequate support for its travel related expenditures, incurred
excessive and/or questionable travel costs, and lacked a system to
properly account for and monitor travel advances and claims.
The Authority lacked adequate support for its travel related expenses.
Travelers were advanced/reimbursed funds without the submission of
appropriate travel documentation. Travelers were not required to submit
receipts to support costs claimed or paid. However, when travel
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documentation was submitted, it was often either 1) modified; 2) belonged
to other travelers; 3) dated outside the travel time to support costs
claimed; and/or 4) vague and/or inadequate as to the need and purpose of
the travel. As a result, the Authority is unable to identify what actual
travel was incurred; whether claimed costs were valid; whether or not
travelers were correctly compensated; or whether travelers had been
over advanced and owed a refund to the Authority.
The Authority has not been adequately implementing its occupancy and
Deficient occupancy leasing policies and procedures. More specifically, the Authority was not
and leasing procedures performing certifications in a timely manner, and was not properly
verifying tenant income information. Therefore, the Authority was not
able to ensure that its tenants were being assessed the correct monthly
rental charges. In addition the Authority was deficient in its overall
leasing activities. The Authority allowed new move-ins to reside in their
units for up to two months free of rent. Also the Authority was not
properly filling out many of its housing leasing documents, and was not
charging all of its tenants rent.
The Authority did not have an effective collection procedure. As of the
September 30, 1995, the amount due from its tenants totaled $526,446.
However, this amount had increased by twenty-four percent through
September 30, 1998 when the accounts receivable totaled $695,017. This
total does not take into consideration the $50,728 in costs chargeable to
tenants for tenant caused damages that were not recorded on the
Authority’s books of accounts as a receivable from the applicable
tenants.
The Authority has failed to maintain preventive controls over its cash
Better controls are receipts. The Authority’s implemented cash collection system primarily
needed over cash vested all the functions of handling Authority monies and the function of
receipts recording cash collection transactions on the Authority’s books of
account with the same Authority staff member. Normally, a proper
system of internal control over cash would separate these two functions.
Also, the Authority was not depositing its monies timely and intact. More
specifically, Authority collections were held for up to 79 days before
being deposited. Cash receipt tickets were not always issued in
numerical sequence. As a result, the Authority has limited assurance that
its cash collections have been properly deposited into the Authority’s
bank accounts and correctly recorded on its books of account.
The functions of receiving and handling cash receipts as well as recording
and controlling related accounting transactions being performed or
controlled primarily by the same Authority employee becomes more
significant since this employee is also responsible for maintaining the key
functions relating to the occupancy and leasing of Authority’s housing
units, as well as collecting delinquent tenant accounts.
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Overall, the Authority needs to establish adequate procedures for
Overall, effective carrying out the directives of the Authority Board and ensuring the
management controls compliance with HUD housing program requirements. Such procedures
are needed would relate to the operating areas of the Authority and include the
established funded housing programs of housing construction, travel,
occupancy and leasing, and cash. Also, the procedures should be divided
amount the Authority staff so that the functions of handling an Authority
asset are separate from the functions of recording the transactions
relating to the asset.
The results of the audit were discussed with officials of the Authority
Auditee Comments during the course of the audit. The draft audit report was submitted to
the Authority on July 27, 2000 for their review and comments. The
Authority’s written comments dated August 21, 2000 were received by
us on September 22, 2000. We have incorporated the Authority’s
comments into the report as applicable and the complete written response
in included in Appendix 2.
The Authority’s written response pointed out that the Authority staff and
Board of Commissioners have spent a great deal of the past four years
reviewing, modifying and correcting the Authority’s operations. The
latest HUD Monitoring Report did not list any findings but only concerns.
Corrective action has been taken to implement the recommendations and
to alleviate any further concerns. In addition, the Authority points out that
the 1998 independent audit report issued an unqualified opinion for the
financial statements and only had one concern dealing a problem in the
occupancy area.
For each of four major problems areas discussed in the audit finding, the
Authority provided a history, related position and resolution action to be
taken. Basically, the Authority has initiated steps to correction the
conditions cited in the finding and will continue to do so to address our
areas of concern. The present goal of the Authority administration and
staff is to close the high-risk determination by correcting all outstanding
findings/concerns and to finally receive a clean audit.
We had incorporated the Authority comments to each of the four key
problem areas in the finding. We have also provided any clarifying
explanation as necessary.
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Table of Contents
Management Memorandum......................................................................... i
Executive Summary...................................................................................iii
Table of Contents ....................................................................................vii
Abbreviations ........................................................................................ viii
Introduction.............................................................................................. 1
Finding and Recommendations
1. Deficient Authority Management Controls Over Its
Housing Operations .................................................................... 5
Management Controls ..............................................................................29
Follow-up on Prior Audits........................................................................31
Appendices
1. Schedule of Questioned Costs ...................................................33
2. Auditee Comments ....................................................................35
3. Distribution ...............................................................................41
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Abbreviations:
HUD Department of Housing and Urban Development
NAHASDA Native American Housing Assistance and Self Determination Act
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Introduction
The Chippewa Cree Housing Authority (Authority) was established by the Chippewa Cree Tribal
Business Committee on April 4, 1963. The Authority was created to provide for safe and sanitary
dwelling accommodations for the residents of the Rocky Boy Indian Reservation. The Authority is
governed by a five member Board of Commissioners, appointed by the Chippewa Cree Tribal Council.
The Board has the overall responsibility for the operation and direction of the Authority’s activities. This
includes the formulation of various policies and procedures to be followed in carrying out the Authority’s
housing activities. The Board has established the position of the Executive Director to implement the
Board’s policies and procedures and to direct the overall day to day operation of the Authority.
Through September 30, 1997, the Authority received funding from HUD under three Annual Contributions
Contracts for the development and administration of its Low Rent Housing Program and the two Mutual
Self Help Housing Programs. Under these contracts HUD has provided $33,661,235 to develop 531 units
of housing. The Authority received about $22 million of the $33 million during the forty-four months of our
audit period. In addition, the Authority received $5,031,493 in Comprehensive Improvement and
Assistance Program and Comprehensive Grant funds to modernize a portion of these 531 housing units.
Effective October 1, 1997, the Authority no longer received funding under the HUD Annual Contributions
Contracts but began receiving HUD funding under the Native American Housing Assistance and Self-
Determination Act of 1996 (NAHASDA). Under the provisions of the Act, the Authority was designated
by the Chippewa Cree Tribe as the Tribal Designated Housing Entity to receive and implement housing
grants to provide housing assistance under the Act. The total NAHASDA funding provided to the
Authority for fiscal years 1998 and 1999 was about $4.5 million.
The accounting records of the Authority are maintained by RAM Enterprises of Aberdeen, South Dakota.
The Authority’s administrative office is located on the Rocky Boy Reservation, Montana.
PRIOR ADMINISTRATIVE REVIEWS OF THE AUTHORITY
During fiscal year 1996, the HUD Northern Plains Office of Native American Programs became aware
that the Authority was experiencing financial and administrative difficulties. The Authority was cited by
HUD as having extremely high Tenant Accounts Receivable balances, Line of Credit Control System
draw downs for Comprehensive Grant and Development expenditures that did not have appropriate source
documentation, a minimum amount of cash on hand for a period of time, no investments, improper use of
HUD development funds, and issues with the Authority’s management of the tenant waiting list
procedures. At one point, the Authority’s fee accountant, contacted HUD stating that the Authority had a
negative cash position and asked that subsidy payments for May, 1996 be advanced to cover the cash
shortfall.
The Authority’s financial difficulties during fiscal year 1996 were not only due to their fiscal
mismanagement, but due to the expending of funds for a log home kit and foundation work. These
expenditures, along with other financial obligations, lead the Authority to obtain five lines of credit with two
financial institutions with a combined maximum loan amount of $675,100. These lines of credit were
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established between July, 1995 and September, 1996. The Authority pledged current and future HUD
program funds for four of the five lines of credit. According to Board meeting minutes, part of the lines of
credit were used to cover Comprehensive Grant Program payroll, as well as expenditures related to the
log home kit and foundation work. These issues and/or difficulties eventually led to the issuance of a
HUD’s Corrective Action Order and High Risk Determination on December 19, 1996.
The December 19, 1996 Corrective Action Order declared the Authority High Risk under Title 24, Code
of Federal Regulations, Part 85. The Corrective Action Order identified the existence of regulatory
deficiencies relating to Title 24 Code of Federal Regulations Part 950.135 and Part 85.20. The Corrective
Action Order stated the Authority:
1) Lacked administrative capability in the area of general financial management, management
systems and housing development;
2) Was in non-compliance in the financial administration of grants;
3) Had not selected housing applicants in accordance with their waiting lists; and
4) Had other management deficiencies that were supported by audits, on-site reviews or other
reliable information.
The Corrective Action Order also noted that the Housing Authority did not:
1) Hold Board meetings in compliance with its By-laws;
2) Have properly trained and competent personnel at key management positions;
3) Maintain a stable financial position;
4) Maintain an appropriate financial management systems;
5) Convert initial development grant for Low Rent Project; and
6) Select participants in accordance with the Mutual Help or Low Rent Housing Program
waiting lists.
In addition, HUD identified five specific management deficiencies at the Authority in the following areas:
1) user fees; 2) budget overruns; 3) tenant accounts receivable; 4) other sources of income; and 5) audit
findings.
During the week of August 30, 1999, staff of the Northern Plains Office of Native American Programs
conducted an on-site monitoring review of the Authority’s Indian Housing Block Grant program funded
under the NAHASDA. Their draft report was submitted to the Authority for comment on November 16,
1999. After receiving the Authority’s comments, the Northern Plains Office of Native American
Programs issued on February 22, 2000 to the Chippewa Cree Tribe their Final Monitoring Review Report
and High Risk Designation for Indian Housing Block Grant on the Authority.
The High Risk designation was for the Authority’s 1998 and 1999 Indian Housing Block Grants and was
based on the Authority’s independent public accountant’s disclaimer of opinion audit report for the 1996
fiscal year. The disclaimer related to the Authority’s financial statements and compliance with general
requirements. The Authority was apprised the High Risk determination would continue until the 1998
independent audit report was received and the auditor issued a unqualified opinion and there were no
significant findings regarding financial management. The audit results would be reviewed by HUD and a
determination made as to whether the High Risk determination would impact the 2000 fiscal year Indian
Housing Block Grant program.
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HUD notified the Authority on March 21, 2000 that their Indian Housing Plan submitted for their Indian
Housing Block Grant Program was acceptable. In addition, the letter also continued the High Risk
Determination for the Authority.
Subsequent to the issuance of HUD’s Final Monitoring Review Report and High Risk Designation for
Indian Housing Block Grant, the Authority’s independent public accountant issued their report for the 1998
fiscal year. This report. dated May 27, 1999, contained an unqualified opinion. However, the audit report
identified the following findings:
• Material weakness identified in the internal control over financial reporting;
• Reportable conditions were identified that were not considered to be material weaknesses in the
internal control over financial reporting; and
• Material weakness were identified in the internal control over major programs.
Findings presented in the audit report related to payroll records, tenant and homebuyer receivables, fixed
assets, year 2000 compatible readiness issues, tenant and homebuyer receipts, and tenant and homebuyer
files.
Correspondence in connection with these reports between the Authority and HUD indicate that
improvements are being pursued in the Authority’s internal controls over its housing operations.
OFFICE OF AUDIT REVIEW RESULTS
Our review identified basically the same conditions that have been presented by reports of both HUD and
the Authority’s independent public accountant. We identified that the Authority’s management control
structure over its various housing operations are deficient and need to be established and/or strengthened.
The objectives of the audit were to evaluate the:
Audit Objectives and
Methodology
• Housing Authority’s expenditure of funds for two log homes and
management’s involvement in developing these log homes;
• Management controls related to the operations of the Housing
Authority and identify any deficiencies or potential problem areas in
the controls; and
• Determine if there were questionable, unsupported, or inappropriate
transactions.
Our audit approach was to identify and evaluate the management controls
in place over the key areas of operations of the Authority with the
established policies and procedures adopted by the Authority’s Board of
Commissioners. During the review, we examined accounting records and
other documents of the Authority, the Authority’s fee accountant and
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HUD’s Northern Plains Office of Native American Programs. We also
conducted interviews with employees of these organizations.
Our audit generally covered the period of January 1, 1995 through
Scope
September 30, 1998 and was expanded, as necessary, to fully accomplish
our audit objectives. We conducted our review from January 1998
through October 1999. The performance of our review was interrupted
by the uncontrolled changes of assigned audit staff.
Our review was performed in accordance with generally accepted
Generally Accepted government auditing standards taking into consideration the limitation
Government Auditing specified in the scope paragraph above.
Standards
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Finding
Deficient Authority Management Controls Over Its Housing
Operations
Our review of select sections of the Authority’s housing operations identified areas whereby the Authority
was not effectively and efficiently administering its housing program and in conformity with HUD
requirements. Primarily, the Authority had authorized and used HUD funded monies, totaling $126,679, to
fund its own separate non-HUD housing program. In addition, the Authority had not formulated and
implemented proper management controls over its travel, occupancy and leasing, and cash receipts.
Authority travel has been permitted whereby unallowable, undocumented, excessive and improper
documented costs were incurred. Our review of three out-of-town trips taken by Authority Board
members and/or employees disclosed improprieties in the support and reimbursements for the travel. As a
result, the total cost of the three trips of $27,139 is questionable as being valid Authority travel costs.
The Authority has not been adequately implementing its occupancy and leasing policies and procedures.
Primarily the Authority has not performed its tenants’ certifications in a timely manner, and was not
properly verifying tenant income information. In addition the Authority was deficient in its overall leasing
activities. The Authority allowed new move-ins to reside in their units for up to two months free of rent,
leasing documents were improperly filled out, and not all of its tenants were being charged rent.
Cash receipt control procedures have been deficient since all monies have not been deposited timely and
intact. Cash receipt tickets have been issued out of sequence while all receipt tickets have not been
accounted for. In addition, all the functions dealing with the handling and recording of cash receipts have
been vested in or controlled by the same Authority employee. This same employee also administers the
main functions of establishing and calculating tenant charges as well as maintaining and recording the
official Authority tenant files and records.
These deficiencies stem from the failure of the Authority to formulate adequate management control
procedures to ensure that the policies and procedures as adopted and directed by the Board are correctly
implemented and followed by the Authority staff.
HUD’s Annual Contributions Contract with the Authority required the
Authority must comply
Authority to carry out its HUD-funded housing programs in an economic
with HUD requirements
and efficient manner, only fund HUD authorized activities, and comply
with the various requirements specified by HUD. Title 24 of the Code of
Federal Regulations, Part 85, requires the Authority to maintain adequate
accounting records, have effective control and accountability, and have
proper supporting documentation for its housing activities and related
costs.
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In addition the Authority is to establish various policies and procedures
governing the various aspects of its housing operation. These policies and
procedures are established by the Authority Board of Commissioners and
form the framework for the Authority staff to administer its housing
programs.
Our review identified that the Authority has not established adequate
Adequate management management controls over its various housing operations and activities.
controls have not been While policies and procedures have been followed, these have not been
established and followed sufficient to ensure the Authority that its HUD funded housing program
and activities are being conducted in accordance with the established
HUD and Authority requirements.
The Authority used HUD program monies to fund its non-HUD housing
program. In addition, the Authority lacked adequate controls over its
travel, tenant leasing and occupancy, cash receipts, and maintenance.
These items are discussed in the following four sections:
1. HUD Funds Totaling $126,679 Used to Finance Non-HUD
Housing Activities
HUD monies used to Contrary to the provisions of the Annual Contributions Contract, the
fund $126,679 of Authority used HUD program funds totaling $126,679 to finance their
Authority’s non-HUD separate non-HUD housing acquisition program. The Authority’s
housing acquisition acquisition program was designed to help persons acquire homes. The
program monies were used in an attempt to acquire two log homes and for legal
fees in resolving a contract dispute related to one of the log homes. The
log homes were to be acquired for the former Authority Board Chairman
and his brother.
The Authority in November, 1995 inquired of HUD if HUD housing
HUD apprised development funds could be used to fund their acquisition program. The
Authority not to use intent was to sell the homes upon completion and then to use the
HUD monies for non- proceeds to fund other similar housing units. HUD notified the Authority
HUD activities in February, 1996 that HUD program monies could not be used to fund
the Authority’s new acquisition program.
Because the Authority was incurring financial difficulty, the Authority
established five lines of credit with two financial institutions with a
combined maximum loan amount of $675,100. These lines of credit were
established between July, 1995 and September, 1996. According to the
current Authority Executive Director, the lines of credit were to be used
to fund the new acquisition program and pending HUD grant awards.
The Authority pledged current and future HUD program funds for four of
the lines of credit.
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The Authority drew down and used $200,236 of the lines of credit to fund
Ineligible loan interest of the acquisition of the Chairman’s log home, the foundation for a log home
$7,680 paid on financial for the Chairman’s brother, and other Authority expenditures. The loans
institution lines of credit were repaid with HUD program monies. Because of the loans, the
Authority paid $7,680 in interest expense. The $7,680 is an ineligible
HUD program expense under the provisions of the Annual Contributions
Contract and related regulations in Section 85.20(b)(5) of Title 24 of the
Code of Federal Regulations and the Office of Management and Budget
Circular A-87.
On December 30, 1995, the former Board Chairman entered into an
Ineligible acquisition of
agreement with the log home company for the acquisition and
log home for $91,508
construction of a log home to be built on the former Chairman’s existing
foundation. The Agreement specified a purchase price of $89,070. Even
though the Authority was not a party to the agreement, the Authority
began making periodic payments in February, 1996 on the log home.
Four periodic payments totaling $91,508 combined were made by the
Authority in 1996. The basis for the additional payment of $2,438 for the
log home could not be determined. The total payment of $91,508 is an
ineligible HUD program cost since the acquisition was part of the
Authority’s own acquisition program and not part of any HUD funded
housing program.
In June, 1996, a contract dispute began between the log home company
and the Authority over the log home. While the Authority continued to
make periodic payments, the log home company did not deliver and
construct the home. Due to the dispute, the Authority had incurred legal
costs of $24,014 as of January, 1999 in trying the resolve the situation.
On December 24, 1997, the Authority purchased all rights and title to the
log home from the former Board Chairman for one dollar. The former
Chairman also agreed to pay the Authority the difference, if any, between
the amount the Authority paid for the log home and the amount they
received from the sale of the log home since the log home company had
purportedly sold the home to another party.
The Authority’s attorney apprised HUD in August, 1999, a settlement
had been reached with the company whereby the company would repay
the Authority $60,000, about $31,500 less than had been paid. However,
the company has filed for Chapter 13 Bankruptcy Reorganization and
listed the debt to the Authority as part of the reorganization. The
Authority’s attorney believes the company will have two years to pay the
debt and the Authority will receive the $60,000.
The second log home was contracted by the former Chairman’s brother
Ineligible $27,491 paid
from the same log home company. However, there was not a foundation
for second log home
to place the home. The Authority authorized payments totaling $27,491
foundation
for the construction of the foundation.
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The use of HUD monies to finance the construction of the foundation for
the second property is an ineligible HUD program cost. In May, 1998,
the former Chairman’s brother entered into an agreement with the
Authority to repay the $27,491 in monthly installments of $50. At the
repayment rate of $50 a month, the $27,491 will take 45 years to repay.
Also, the Authority has not charged any interest on the $27,491.
In total, the Authority has used HUD monies of $126,679 to finance its
separate housing acquisition program. These consist of:
Interest on line of credit loans $ 7,680
Log home for former Board Chairman $ 91,508
Foundation for second log home $ 27,491
Total ineligible cost $126,679
This situation occurred because the former Authority Board and
Recovery and proper
Executive Director failed to administer the HUD programs under their
use of ineligible costs of
control in accordance with HUD requirements but instead used HUD
$126,679 needed
monies to finance their separate non-HUD funded housing acquisition
program. This was done even though HUD apprised the Authority
against the use of HUD monies to finance its separate housing acquisition
program. Because of the unauthorized used of HUD program funds,
HUD issued administrative sanctions against the former Authority Board
members and Executive Director.
Since the Authority improperly used HUD program monies for its non-
HUD housing activities contrary to specific HUD instructions, the
Authority needs to repay the $126,679 from non-Federal funds and use
the monies for eligible HUD housing program activities.
The Authority in its written comments to the draft audit report (see
Authority Comments
Appendix 2) provided detailed information and explanation on their non-
HUD housing program and how their program was unsuccessful. The
Authority stated that they would follow the recommendations set forth by
HUD.
2. Inadequate Management Control Over Authority Travel and
Related Costs
Under the provisions specified in Part 85, Title 24 of the Code of Federal
Travel costs are to be
Regulations, the Authority is to have:
properly controlled,
supported and allowable
• Accurate, current and complete disclosure of program financial
activities;
• Accounting records, as specified by HUD, to adequately identify the
source and application of HUD program monies;
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• Effective internal control and accountability of all program cash and
other assets that must be safeguarded to ensure that they are used
solely for authorized program purposes; and
• Procedures to ensure only HUD allowable costs are charged to the
HUD housing programs and are properly supported.
We found during the audit period, the Authority failed to implement and
Authority lacked proper
exercise adequate controls over its travel related activities and
accountability and
expenditures. As a result, excessive, unsupported and/or questionable
controls over its travel
costs were charged to the HUD-funded housing programs. Any intended
controls were negated or minimized. More specifically, the Authority
lacked adequate support for its travel related expenditures, incurred
excessive and/or questionable travel costs, and lacked a system to
properly account for and monitor travel advances and claims.
The Authority lacked adequate support for its travel related expenses.
Travelers were advanced/reimbursed funds without the submission of
appropriate travel documentation. Travelers were not required to submit
receipts to support costs claimed or paid. More specifically, when travel
documentation was submitted, it was either 1) modified; 2) belonged to
other travelers; 3) dated outside the travel time to support costs claimed;
and/or 4) vague and/or undocumented as to the purpose of the travel. As
a result, the Authority is unable to identify what actual travel was
incurred; whether claimed costs were valid; whether or not travelers
were correctly compensated; or if travelers had been over advanced and
owed a refund to the Authority.
These deficiencies are illustrated in the following three examples:
Washington, DC - February 29 through March 1, 1996 The Authority
Questionable travel
paid $10,148 for six Authority officials to attend the National American
costs of $10,148 for
Indian Housing Council’s 2nd Annual Legislative Conference in
conference in
Washington, DC on February 29 through March 1, 1996. The Authority
Washington, DC
paid per diem for the travelers for travel beginning as early as February
23, 1996, some six days prior to the start of the conference. Any time in
excess of one day for travel before the conference would be considered
personal travel and ineligible for funding by the Authority.
Three travelers submitted a Travel Claim for their travel. However, the
three used the same hotel receipt to support their lodging cost. If the
travelers did not incur any lodging costs, then they would not be entitled to
the full per diem for which they were paid. The other three travelers did
not submitted any Travel Claim nor receipts for their travel.
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Information furnished by the National American Indian Housing Council
showed that only two of the travelers attended the conference. As a
result, a determination could not be made as to what actual travel was
incurred and how such travel was for official Authority related activities.
The travelers that did not attend the conference needed to reimburse the
Authority for the travel expenditures they were paid. We were unable to
substantiate that the necessary reimbursements were made to the
Authority.
Due to the lack of adequate supporting documentation for the travel costs
paid, the total cost of $10,148 is questionable as a valid HUD housing
program cost.
Reno, Nevada - April 15 through April 18, 1996 Eight Authority staff and
Questionable travel
Board Members were paid a combined total of $13,181 to attend the
costs of $13,181 for
South Western Indian Housing Association and United Native American
meeting in Reno,
Housing Association Quarterly Meeting held in Reno, Nevada on April 15
Nevada
through 18, 1996. All eight travelers were paid for the use of their
personal vehicles to travel to Reno and given six days of per diem that
included a day before and a day after the conference for travel.
Supporting documentation for the trip was very limited. Of the eight
travelers, only four submitted a Travel Claim upon return. Of the four,
two submitted the same lodging receipts. If lodging costs were not
incurred by the one traveler, then the traveler would not have been
entitled to the full day per diem.
The following are some discrepancies noted in the review of the available
documentation:
• Traveler 1 was paid per diem for the six days of travel. While the
per diem includes the cost of lodging, the traveler was also
reimbursed an additional $278 for lodging that was charged on the
traveler’s personal credit card. In addition, the traveler did not submit
a Travel Claim nor receipts to support the initial advance and
reimbursement for lodging costs. Therefore, the total amount of
$1,743 paid for Traveler’s travel costs is questionable.
• Traveler 2 was provided an advance to use a personal vehicle to
attend the conference. In addition, the Authority paid $680 for air
fare to the conference when the traveler changed his mode of travel.
The Travel Claim submitted by the traveler did not indicate whether
the traveler drove or flew to the conference.
Traveler 2 was paid for seven days of per diem rather than for six
days that would be needed to attend the conference. A lodging
receipt submitted by the traveler indicated the traveler only attended
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the conference on September 16, 1999. However, this receipt was
for another Authority traveler.
Traveler 2 also included with the Travel Claim receipts for lodging in
Dillon, Montana on April 17, 1996, which was the second day of the
conference in Reno, Nevada. The Dillon lodging receipts which
appeared to have been modified indicating two rooms were rented.
The need for two lodging rooms for a single night by the traveler is
unknown. As a result, a determination could not be made as to the
exact nature and extent of travel incurred by this traveler and the
total travel amount of $1,725 paid for the travel is questionable.
• Traveler 3 received a total of $1,395 to attend the conference. The
lodging receipts submitted by the traveler were the same as for
Traveler 2. More specifically, the traveler submitted a receipt for
lodging in Dillon, Montana on April 17, 1996 that was the same as for
Traveler 2 except that the occupant’s name and arrival and departure
dates had been modified. Accordingly, the nature and extent of the
travel incurred by Traveler 3 could not be determined and the total
travel amount of $l,395 paid is questionable as a proper Authority
program cost.
Due to the conflicting nature and lack of specific travel documentation,
the extent of travel costs incurred for the conference is unclear.
Therefore, the costs of $13,181 paid by the Authority is questionable as a
valid housing program expenditure.
Tampa, Florida - June 8 through 10, 1998 The Executive Director and
Questionable travel
two Authority Board members were paid $3,810 to attend the National
costs of $3,810 for trip
American Indian Housing Council’s 24th Annual Convention and Trade
to Tampa, Florida
Show in Tampa, Florida from June 8 through June 10, 1998. However,
the Authority paid the travelers per diem for three days before and two
days after the conference. These days in part would be considered
personal travel and not reimbursable by the Authority.
The supporting documentation was very limited. Only two of the three
travelers submitted a Travel Claim. Only one of these two travelers
submitted receipts to support the costs claimed. The following
discrepancies were noted in the review of the available supporting
documentation.
• Lodging receipt submitted for four nights in Tampa, Florida from June
6 through June 10, 1998 by Traveler 1 detailed that the room was
registered to Traveler 2. Therefore, Traveler 1 would not be entitled
to the full per diem amount that was paid.
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• A submitted gas receipt ticket showed Traveler 1 in Great Falls,
Montana on June 10, 1998, the last day of the conference in Tampa.
However, the Travel Claim submitted by Traveler 1 indicated the
traveler was in Tampa until June 12, 1998. The appropriateness of
the two additional days of per diem claimed by Traveler 1 is
questionable.
• Traveler 2 submitted a Travel Claim but no receipts were provided to
support the travel costs claimed. In addition, Traveler 3 did not
submit any Travel Claim. As a result, the nature and extent of the
travel incurred by these two travelers is questionable.
Due to the conflicting nature of supporting documentation that was
provided as well as unsupported or missing Travel Claims, the extent of
the travel incurred could not be determined and the total amount of $3,810
paid is questionable as a valid housing program expenditure.
These sampled Authority travel and related costs illustrate that the
Authority lacks
Authority lacks sufficient meaningful control over its travel activities.
adequate control over
Mainly, the Authority is unable to determine whether planned travel by an
its travel activities and
Authority official actually occurred; travel cost reimbursement was
related costs
properly supported and in accordance with the Authority’s official travel
policy; and any excess advances paid to a traveler were repaid to the
Authority.
For the travelers that do submit a Travel Claim, the Authority does not
reconcile by individual traveler the estimated travel costs to actual travel
costs incurred. Amounts claimed by travelers who file Travel Claims are
the total amount advanced rather that the actual amount incurred. The
Travel Claim form is a recap of amounts advanced per the individual
Application for Travel rather that the actual travel costs incurred and
allowed. This makes it difficult for the Authority to identify: 1) the exact
amount of travel costs incurred; 2) whether travelers were properly
compensated; and 3) whether the Authority is owed monies due to over
advancement. The Authority’s procedures negate the need for
supporting documentation, resulting in excessive and/or questionable
travel costs.
We identified that the Authority does maintain an informal manual record
Informal manual travel
relating to the repayment of advances by those Authority travelers who
record is partially used
do not take a trip for which the traveler was advanced travel funds.
However, we noted the following deficiencies in the recording and use of
the informal manual record in controlling and receiving travel advance
prepayments:
• Manual records are not reconciled to the Authority’s official books of
account;
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• Manual records do not identify all trips by which the traveler did not
take an authorized trip;
• Some travelers do not make any repayments or only pay for a portion
of the entire amount advanced; and
• Some travelers have taken up to three or more years to repay the
travel advance resulting in an interest free loan to the traveler.
As a result, the manual record is inadequate in identifying and controlling
the repayment of travel advances for those individuals who do not take an
authorized trip.
We also identified that the Authority posts the travel advance directly as
Travel costs not clearly
an expense while any repayment are classified as other income. The
identified in the official
impact is that the Authority can only identify whether a traveler has
books of account
properly repaid any excess advances by performing a detailed analysis of
the Authority’s accounting records.
No records are established and maintained by the Authority to identify
those travelers who fail to submit a Travel Claim with the proper
documentation for each trip that a travel advance is made.
The Authority’s inadequate control over its travel costs stems from the
Proper internal controls
following causes:
over Authority travel
and related costs
• Specific procedures are not established for the traveler to be required
to submit a Travel Claim immediately after a trip is taken detailing the
actual travel incurred supported with accurate detailed
documentation;
• Travel Claims are not reviewed for proper support and conformity
with the established Authority Travel Policy; and
• Travel advances are not recorded as a receivable on the official
books of account until the Travel Claim is received and correctly
processed.
Only with proper internal controls over its travel related activities and
expenditures can the Authority be assured that costs incurred are indeed
appropriate, necessary and eligible. This becomes more important since
the Authority under the present Indian Housing Block Grant Program has
limited resources with which to administer its travel related activities and
costs and to maintain its housing stock.
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The Authority in its written comments to the draft audit report (see
Authority Comments
Appendix 2) stated that the past administration and Board of
Commissioners did not plan their travel well and last minute details of the
trips were given to support staff for construction of the travel voucher,
resulting in poor management of operating costs. Also, the Authority
added that financial staff members had little control of the Commissioners
and favored staff that traveled to provide documentation upon their travel
return.
In connection with attending the Native American organizational
meetings, the attending staff and commissioners did not sign in at the
meeting so not to be charged the attendance fee. For the Tampa trip, the
finance officer determined that a Saturday stay over was necessary.
Also the response indicates that receipts for the Tampa trip and a copy of
the Travel Policy was attached; but these were not included.
The Authority points out that their travel policy does not prohibit sharing
the cost of a motel room. Furthermore, the policy followed by the
Authority is patterned after the Tribe’s policy and this policy does not
require meal receipts.
In summary, the Authority stated the new travel policy prohibits the abuse
that was evident in the past and the travelers will adhere to the
Authority’s Travel Policy. In addition, the Authority will in the future
provide better controls over its travel activities and related costs. Travel
advances will be recorded on the books of accounts as a receivable and
will be offset by the amount of the travel voucher when received.
The Authority’s comments indicate that improvements are being made in
Evaluation of
its procedures over travel and related costs. The Authority does not state
Authority’s comments
whether the policy being followed has been formally adopted by the
Authority Board of Commissioners. This becomes paramount if the
Authority travelers are to know exactly what policy governs Authority
travel. Such adopted policy is a directive from the Board of
Commissioners to be followed by all Authority travelers.
While it may be a common practice for travelers to attend conferences
without registering at the conference in order to forego the payment of a
conference fee, the fact remains that the travel vouchers discussed above
did not provide any documentation to show the traveler actually attended
the meeting or conference. Without the documentation, the Authority can
not determine where the travel advances for the trip should be refunded
to the Authority.
We agree that the policy as followed by the Authority did not prohibit
more that one traveler from sharing a lodging room. However, the use of
one room rent receipt issued to one traveler by other persons would not
entitle the other persons to receive the full amount of per diem. The per
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diem is provided to pay for both lodging and meals. If no lodging cost is
incurred by a traveler, the traveler would only be allowed the meal
reimbursement portion of the per diem. The alteration of another
person’s lodging receipt to obtain lodging reimbursement of per diem is
improper.
3. Inadequate Unit Leasing and Occupancy Procedures
Under the provisions of HUD’s Annual Contribution Contract and
Authority required to subsequently under the Native American Housing Assistance and Self
implement occupancy Determination Act, the Authority is required to establish policies and
and leasing policies and procedures that govern the occupancy and selection process of it housing
procedures tenant. Policies and procedures are to be adopted separately for the Low
Rent and Mutual Help housing programs.
Authority policies and procedures are to provide that occupancy and
Occupancy and leasing
leasing requirements be consistently applied by housing program type.
procedures
Low Rent units are not to be treated as Mutual Help units and Mutual
Help units are not be treated as Low Rent dwellings. Tenant income is to
be properly identified and verified at the time of move-in and annually
thereafter. Tenant charges are to be calculated based upon verified
income. In addition, tenant lease agreements are to be properly
completed and executed with rental charges to be made from the
effective date of the lease on a monthly basis.
The Authority has not been adequately implementing its occupancy and
Deficient occupancy
leasing policies and procedures. More specifically, the Authority has not
and leasing procedures
performed certifications in a timely manner, and was not properly
verifying tenant income information. Therefore, the Authority was unable
to ensure that its tenants were being assessed the correct monthly rental
charges. In addition the Authority was deficient in its overall leasing
activities. The Authority allowed new move-ins to reside in their units for
up to two months free of rent. Also the Authority was not properly filling
out many of its housing leasing documents and was not charging all of its
tenants rent.
Authority and fee accountant records showed that the required annual
Annual Certifications tenant income certifications were not being performed in a timely
not performed timely manner. The importance for the annual certifications is to determine the
yearly income that a tenant receives. This amount is to be used by the
Authority to calculate the amount of monthly rent that the tenant is to
pay.
As of September, 1998, the Authority had not performed eighty-one
percent of its annual certifications. The failure to complete its
certifications prevents the Authority from identifying the income that its
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tenant receive. According, the Authority is unable to properly calculate
the amount of monthly rent each tenant is to be charged.
During our review, we noted that the Authority was deficient in its
Deficient tenant income
verification of tenant income. Tenant files did not contain sufficient
verification procedures
evidence that the Authority had required all income sources to be
reported, independently verified and/or included in calculating the tenant’s
annual income.
To illustrate, the Authority used only the spouse’s income of an Authority
contractor to calculate rent. The tenant’s file did not contain any
documentation detailing the annual income realized by the self-employed
contractor. The tenant’s monthly rental charge was calculated based
solely on the spouse’s income. As a result, the tenant was not assessed
the proper monthly rental charge. Had the correct income been
determined, the tenant may not have met the low income requirements
established by HUD.
The Authority failed to verify and properly document tenant income in its
tenant files. The majority of tenant files reviewed did not provide
sufficient evidence that income information presented was independently
verified by the Authority. More specifically, tenant files contained a
notation detailing a tenant’s income, however, did not contain any formal
documentation (e.g., paycheck stub, W-2’s, etc.) to support the notation.
Therefore, the Authority is unable to demonstrate the income reported on
related certification documentation was indeed correct and that the tenant
was being assessed the correct monthly rental charge.
We also noted that the Authority had improperly computed monthly rent
charges for some of its tenants. In some cases, the Authority had
incorrectly calculated rent as Mutual Help, when the units occupied were
Low Rent. The impact is the housing occupant was being undercharged
their monthly rent. For example, one tenant based upon the income as
reported in the tenant’s file would be charged a monthly rent of $429.50
for their Low Rent dwelling. However, the Authority used the Mutual
Help program to assess the tenant a monthly charge of $128. As a result,
the Low Rent housing unit family was undercharged $301.50 each month.
At the time of our review, the Authority was following the practice of not
New tenants allowed at charging new move-ins tenants rent until two months after they had
least two months free moved into the unit. For example, if a tenant were to move-in on January
rent 1, 1999, the Authority would not begin to charge monthly rent until March
1, 1999.
An Authority official explained that a tenant is allowed to move into a unit
before the Authority actually determines the amount of tenant income and
related monthly rent. The official further explained that it usually takes
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00-DE-207-1004
about two months to complete the income verification and rent
computations.
In addition, we noted three instances whereby new move-in tenants were
allowed to occupy their units for up to ten months free of rent. This
occurred because the Authority had only completed some of the required
certification documentation and were unable to determine the tenant’s
income and related monthly rental charges. As a result, the tenants were
allowed to move into their units at the specified move-in date with a zero
dollar rent charge.
This practice of allowing new tenant at least two months of free rent is
contrary to the lease agreement with the tenant and is not in conformity
with the Authority occupancy policies. The real impact is that the tenant
is not required to pay their appropriate rent from the effective date of the
lease and thereby reducing the amount of revenues the Authority can
receive and use.
At the time of our review, we noted that the Authority was not assessing
Tenants not charged for its tenants for the cost of repairs for tenant caused damages. Authority
repairs of tenant caused records show that for the nineteen month period ending September 30,
damages 1998, the cost of housing repairs for tenant caused damages totaled
$50,728 and these charges had not been recorded on the Authority’s
books of account and assessed against the applicable individual tenants.
The Authority’s election to not charge its tenants for tenant caused
damages is contrary to the provisions of its Maintenance Policy and the
provisions of the lease agreements with its tenants.
In addition, the Authority procedures did not fully account for all issued
work orders, ensure that all repair work and related costs were correctly
recorded on the individual work orders and assessed against the tenants
for tenant caused damages. As a result, the Authority has limited
assurance that all necessary repair work is being performed and that its
tenants are funding the costs of all repairs for which the tenant is
responsible.
At the time of our review, the Authority had formulated a procedure for
not making repairs on units until the tenant had prepaid the cost of the
needed repair. For example, in January 1998, the Authority had 55 work
orders it was holding and was suspending any repairs on tenant caused
damages until such time as the tenant prepays the cost of the repairs. By
following this practice, the number of suspended work orders will
probably increase since the Authority is not actively pursuing the
collection of the repair prepayments. The result of not performing the
repairs can only help to further deteriorate the condition of the
Authority’s dwelling units.
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At the time of our review, we found that many tenant lease agreements
Deficient tenant lease
were not completely filled out. In some cases, tenant leases were blank
agreements
forms that had been signed by the housing tenants. In some cases, the
tenant files contained both Mutual Help and Low Rent Housing Program
leases even though the unit was a Low Rent Housing Program house.
Without properly executed rental leases, the Authority is severely
hampered in enforcing the provisions of the lease and the Authority’s
occupancy requirements.
Prior to April, 1998, the Authority was allowing all of their Low Rent
Inconsistent leasing Housing Program tenants a utility allowance. This allowance was offset
changes without official against the monthly rental charge and provided the tenants with reduced
Authority Board action rents to pay for their utilities. In some cases, the allowance would result
in a tenant having a negative rent amount. In such cases, the Authority
would pay the amount of negative rent to the tenant.
In April, 1998, the Authority staff, after discussions by the Authority
Board but without any official Board action being taken, unilaterally
reduced all negative rents to a “zero” amount. This was done without
formal Authority Board authorization and any amendments to the tenant
lease. This in effect was a reduction in the Authority’s utility allowance
for the very low income tenants. However, the reduced utility allowance
was not granted to those tenant whose monthly rent including the utility
allowance was a positive amount (more than zero).
This unofficial action by the Authority staff resulted in inconsistent
computed rental charges being assessed against its Low Rent Housing
Program tenants. The impact is that some tenants are not granted as
much a utility allowance as other tenants. Furthermore, some tenants are
paying a higher share of their income for their monthly rent than other
tenants.
Per HUD requirements, the Authority is to assure the prompt payment
Authority to follow a and collection of monthly rent charges from its tenants by the
collections policy establishment and implementation of an effective collections policy.
The Authority lacked an aggressive collection procedure. The Authority
Lack of an aggressive was not making a meaningful effort to implement its collection policy or
collection procedures initiate eviction procedures for the non-payment of monthly rent charges.
As a result, tenant accounts receivable continues to increase significantly.
This condition was pointed out in the last Independent Public
Accountant’s report for the fiscal year ending September 30, 1998. This
report states that the increase in tenants accounts receivable has had a
crippling affect upon the Authority. The report states that the tenants
accounts receivable total as of the audit date of September 30, 1998 was
$695,017. When compared to the accounts receivable balance at
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September 30, 1995 which was $526,446, the Authority’s tenant accounts
receivable has increased by twenty-four percent in three years. This
amount does not include the $50,728 in repair costs for the nineteen
month period ending September 30, 1998 the Authority had incurred but
had not charged the applicable tenants for the cost of repairs for tenant
caused damages.
The following table details the average Tenant Accounts Receivable
balance per tenant as of September 1998 for the three types of Authority
housing program:
Average Receivable
Housing Program Balance Per Tenant
Low Rent $249.32
New Mutual Help $986.81
Old Mutual Help $2,464.08
One Board member had an accounts receivable balance of $14,725 as of
September 1998. The last payment for this Board member had been
$37.50 in January 1997. The Authority file for this Board member did not
contain any evidence that the Authority had made a meaningful effort to
collect the balance owed.
The Authority has not formulated any meaningful collection efforts and/or
Authority failed to eviction procedures. The Authority practice has been to send tenants
formulate meaningful with accounts in arrears a letter asking them to come into the Authority to
collection efforts and establish a pay back agreement. Types of pay back agreements included
eviction procedures an increase in the tenant’s monthly payment, and/or a request for direct
deduction of monthly rent charge from the tenant’s paycheck.
During our audit, we reviewed tenant files to determine whether or not
the Authority was establishing and enforcing pay back agreements with
tenants whose accounts were in arrears. In most cases, the Authority
had sent a letter to tenants notifying them that they were in arrears and
needed to establish a pay back agreement with the Authority. However,
the Authority failed to enforce established pay back agreements. In most
cases, tenants reverted back to non-payment of their monthly rent
charge. In addition, there was no evidence in the tenant files that the
Authority had followed up or obtained any response from tenants
regarding their accounts thereafter.
According to Authority occupancy policies and procedures, failure to
meet monthly rent charges, can be cause for eviction. We found that the
Authority did not exercise the use of eviction for non-paying tenants.
Instead, tenants were allowed to remain in their units, while their tenant
accounts receivable balances continued to increase.
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These deficiencies have a significant impact upon the operation of the
Deficient occupancy Authority since the leasing of its housing units is not consistently and
and leasing procedures adequately administered. The practice of improperly verifying income
impact Authority’s and calculating the related monthly rental charge, allowing free rent for
needed revenues new tenants, improperly executed leases agreements and following an
incomplete and ineffective collection and eviction policy greatly hampers
the Authority in assessing and receiving rental income from its housing
occupants. Such revenues are necessary for the effective operation of
the Authority and its housing programs.
These deficiencies stem from two basic causes. The first is lack of
Key causes are lack of
formal policies being adopted by the Board. The second is that the
formal Board
Authority staff has not implemented proper procedures to consistently
Occupancy and Leasing
and properly administer is housing occupancy and leasing activities.
Policy and proper
administrative
As part of the Native American housing Assistance and Self
procedures
Determination Act, the Authority certified to HUD as part of its Annual
Housing Plan that the Authority had formally adopted occupancy and
leasing policies and that these were being followed by the Authority. Our
review as discussed above indicate that the policies have not been
formally adopted by the Authority Board and that the implementation of
the occupancy and leasing activities has been inconsistent and
ineffectively administered.
The Authority’s occupancy and leasing procedures are being
Key occupancy administered without the proper administrative controls. Normally, the
activities vested in same functions of handling program assets and recording of the program
Authority employee transactions are separated. However, at the time of our review, all
functions relating to occupancy and leasing were vested in the same
Authority employee. This employee carried out the following tenant
occupancy and leasing functions:
• Verified tenant income and calculated tenant monthly rents;
• Determined when a new tenant would begin to be charged rent;
• Implemented the Authority’s collection and eviction procedures;
• Maintained the Authority’s official tenant files and records; and
• Recorded and maintained the Authority’s official tenant accounting
records.
This same Authority employee also has the responsibility for assessing
tenants for the cost of repairs for tenant caused damages and for
collecting such repair cost payments.
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00-DE-207-1004
The Authority in its written comments to the draft audit report (see
Authority Comments
Appendix 2) stated the Authority as well as other Tribal housing
authorities have had a history of noncompliance by occupants of their
Low Rent and Mutual Help Housing Program units. In addition, the past
administration, staff members and Tribal Council members advocated
non-payment of housing payments and compliance to recertification to
help or protect their families and relatives from paying rents according to
all income of the household. The trend is ingrained in the present tenants
and homebuyers as the Tribal Council and Tribal justices would not allow
the Authority to evict tenants, terminate homeowners for non-payment or
non-compliance of lease and/or Mutual Help Occupancy Agreements.
This has been done even though Tribal resolutions have been passed
previously mandating all employed individuals to pay their rents and home
payments to the Authority.
The Authority’s written comments state that it will take years of
correcting and re-educating Tribal members the skill of self-reliance.
HUD, through past regulation, and the Tribe have only taught the people
co-dependency on the Authority and Tribal programs to take care of their
needs. Now the Authority must wean them from depending on the
Authority to take care of their unit maintenance and from being the
source of housing, by providing them with the assistance to help
themselves through education, counseling, and home ownership.
The Authority indicates that changes have been make to provide better
separation of management controls over its tenant and occupancy
procedures. Also, the Authority will review and implement the current
Admission, Occupancy, and Internal Control policies. These will be
formally adopted by the Board so the staff will have governing documents
with which to adhere to. Lastly, the Authority states that the
recommendation given will be considered for implementation.
4. Improved Controls Needed Over Cash Receipts
Section 85.20 of Title 24 of the Code of Federal Regulations details the
Proper controls over financial administrative standards for program assets that are to be
cash receipts to be implemented by the Authority. The Authority is to maintain effective
followed controls and accountability over its cash. Adequate procedures are to be
utilized to safeguard the Authority’s cash as well as to ensure that such
monies are used solely for authorized purposes.
A basic component of any internal control system is the separation of
functions for handling and recording cash. The separation of duties
serves as a protection of Authority employees by fixing responsibility and
accountability, and also serves as a deterrent to possible misappropriation
or diversion.
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Prudent business practices for collecting cash receipts dictate that, as a
minimum, the collection and deposit of cash receipts be performed by
different employees. Such separation of functions is necessary if the
Authority is to properly handle and account for its cash receipts as well
as to protect the integrity of its employees.
The Authority has failed to maintain preventive controls over its cash
Better controls are receipts. The Authority’s implemented cash collection system primarily
needed over cash vested all the functions of handling Authority monies and the function of
recording cash collection transactions on the Authority’s books of
account with the same Authority staff member. Normally, a proper
system of internal control over cash would separate these two functions.
Also, the Authority was not depositing its monies timely and intact. More
specifically, Authority collections were held for up to 79 days before
being deposited. Cash receipt tickets were not always issued in
numerical sequence. As a result, the Authority has limited assurance that
its cash collections have been properly deposited into the Authority’s
bank accounts and correctly recorded on its books of account.
At the time of our review, the functions of receiving and handling cash
Main cash receipt receipts as well as recording and controlling related accounting
functions vested with transactions were handled primarily by the same Authority employee.
the same employee The employee performed the key duties for collecting, depositing and
recording cash receipts. The employee accepted tenant payments, issued
cash receipt tickets, maintained custody of the supply of cash receipt
tickets, posted cash collected to the Authority’s automated tenant ledger
system, maintained custody of issued cash receipts, and prepared bank
deposits. In addition, the same person sent accounting information and
records to the Authority’s fee accountant for posting to the Authority’s
official books of account.
This weakness is probably more significant since this employee is also
responsible for maintaining the key functions relating to the occupancy
and leasing of Authority’s housing units as discussed in the previous
section. These key functions include the verification of tenant income,
calculating monthly tenant rents, and maintaining the official tenant files.
In addition, this same employee also performed or controlled the main
functions relating to assessing tenants for tenant caused damages. This
involves the calculation, recording, collecting, and depositing the amount
of charges for tenant caused damages.
During the audit period, the Authority did not always deposit its cash
Cash receipts not collections timely or intact. We noted that monies were held on an
always deposited timely average from a period of three days to sixteen days. In one instance,
and intact monies received from one tenant were held for 79 days before being
deposited.
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The Authority was following the practice of not depositing cash
collections for new tenants until such time as all the required
documentation relating to their occupancy is received and processed
and/or the Authority’s fee accountant had established a tenant account
number for the new resident. This practice greatly reduces the
Authority’s control and accountability over its cash collections and related
deposits by allowing amounts of cash receipts to be kept on hand at the
Authority for extended periods of time. The potential for embezzlement
or theft is therefore greatly increased.
Cash receipts need to be deposited into the Authority’s bank account as
frequently as possible, preferably daily, and intact. Monies should not be
kept on hand until decisions are reached as to how to record the receipts
on the Authority’s books of account.
The Authority utilizes both permanent and temporary receipt tickets in its
Better controls needed cash collection efforts. Permanent receipt tickets are computer issued in
over issued and numerical sequence and generally used when tenants pay their monthly
unissued cash receipt rents. A manual temporary receipt ticket is issued basically when the
tickets tenant computer system is down. Once the computer system is
operational, the temporary receipt ticket is to be voided and a permanent
computerized receipt ticket is issued.
During the audit period, the Authority had not established proper
controls over its issued and unissued cash receipt tickets. The Authority
has followed the practice of issuing cash receipt tickets out of numerical
sequence and failed to formulate any system to account for its issued
tickets. In fact, some issued cash receipts tickets have been missing
without any established follow up procedure.
For example, the Authority’s fee accountant maintains a listing of
permanent receipt tickets that have not been submitted to them for
processing and accordingly, the fee accountant considers them as being
unaccountable or missing. The list of unaccountable or missing receipts,
as of September 1998, listed thirteen receipt ticket numbers. While
Authority officials stated that some of these have been missing for over
ten years, no documented action has been taken to locate and/or provide
the necessary information to the fee accountant for appropriate recording
to the books of account.
In addition, we noted that:
• Temporary receipt tickets are often issued out of sequence;
• Issued temporary receipt tickets are often not marked to show that
they have been replaced by a permanent receipt ticket; and
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• Original voided cash receipt tickets are not always kept and
forwarded to the Authority’s fee accountant.
Without issuing cash receipt tickets in numerical order and properly
accounting for all issued and voided tickets, the Authority has reduced
accountability over its collections. As a result, errors, unintentional or not,
can go undetected.
The Authority has established various procedures that lend itself to
Established Authority formulating a system of checks and balances over its cash receipts.
accountability of cash However, these procedures fall short of providing for adequate controls
receipts is limited and accountability over its cash receipts.
The established Authority procedures consist basically of actual deposit
and related cash receipt ticket information being given to the Authority
Executive Director and the Bookkeeper for their review and concurrence
after a deposit has occurred. This information includes an adding
machine tape of the cash receipt tickets issued, copy of validated deposit
slip from the bank and a Cash Receipts Control Sheet that lists the
deposit amount and the receipt ticket numbers that were issued.
The Authority’s process only accounts for monies once they are
deposited. No control procedures are in place in the three vulnerable
function areas relating to the receiving of monies collected, issuing and
cash receipt tickets, and recording cash transactions.
The Authority’s cash control procedures can be greatly improved by
separating the functions of handling cash collections from the functions of
recording cash transactions. This separation would also need to account
for all issued, unissued, and voided receipt tickets. This would provide the
Authority with increased assurance that all cash collections are correctly
received and deposited and properly recorded in the Authority’s books of
account. The revised procedures would also help to protect the integrity
of its employees.
The Authority in its written comments to the draft audit report (see
Authority Comments
Appendix 2) stated they do not have any history as to why the receipts
were recorded out of order not can they explain the missing receipts.
Also, Authority administration was not aware that tenants were not
charged for work completed on tenant abuse work orders
The Authority further commented that steps have been taken to improve
its management controls over its cash receipts as well as for its
occupancy and leasing activities. The Authority indicated they will
incorporate the recommendation suggested in the report.
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In summary, these four sections discuss in detail the need for the
Overall, effective Authority to establish and implement adequate management controls and
management controls procedures over its housing program activities. These areas deal with the
are needed disbursement of Authority program funds without proper authority and/or
adequate documentation. HUD program funds totaling at least $126,679
were used to finance a separate unauthorized housing program.
Authority travel has been permitted whereby unallowable, undocumented,
excessive and improper documented costs have been incurred. This is
illustrated by the fact that three out-of-town conference or meeting trips
we reviewed showed that the cumulative cost of $27,139 is questionable
as being valid Authority travel expenditures.
The Authority has not been adequately implementing its occupancy and
leasing policies and procedures. Primarily the Authority has not
performed its tenants’ certifications in a timely manner, and was not
properly verifying tenant income information. In addition the Authority
was deficient in its overall leasing activities. The Authority allowed new
move-ins to reside in their units for up to two months free of rent, leasing
documents were improperly filled out, and not all of its tenants were being
charged rent.
Cash receipt control procedures have been deficient since all monies
have not been deposited timely and intact. Cash receipt tickets have
been issued out of sequence while all receipt tickets have not been
accounted for. In addition, all the functions dealing with the handling and
recording of cash receipts have been vested in or controlled by the same
Authority employee. This same employee also administers the main
functions of establishing and calculating tenant charges as well as
maintaining and recording the official Authority tenant files and records.
Overall, the Authority needs to establish adequate procedures for
carrying out the directives of the Authority Board and ensuring the
compliance with HUD housing program requirements. Such procedures
would relate to the operating areas of the Authority and include the
established funded housing programs of housing construction, travel,
occupancy and leasing and cash. Also, the procedures should be divided
among the Authority staff that the functions of handling an Authority
asset is separate from the functions of recording the transactions relating
to the asset.
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RECOMMENDATIONS We recommend that the Northern Plains Office of Native American
Programs require the Authority to:
1A Formally adopt by Board action all policies and procedures that the
Board wants the Authority to implement and follow. This will
include all policies and procedures the Board has previously
intended the Authority to implement but may not have officially
adopted them by formal Board action. These policies and
procedures will need to include those the Authority certified in their
last Indian Housing Block Grant application to HUD as having been
formally Board adopted and followed by the Authority.
1B Establish and maintain the appropriate management control
procedures over its housing operations to ensure that all the policies
and procedures as adopted by the Authority Board are being
implemented by the Authority staff. These would specifically apply
to (1) housing activities as detailed in the Authority annual housing
plan, (2) travel, (3) leasing and occupancy, and (4) cash receipts.
This would ensure that the conditions detailed in the finding for the
four main areas are remedied and proper safeguards and checks
and balances are installed to prevent the reoccurrence of the
deficiencies identified.
1C Require the Authority to reimburse from non-Federal sources those
HUD program costs of $126,679 that were used to finance its non-
HUD housing Activities. Afterwards, these repaid funds would
need to be used to fund eligible housing program activities.
1D Provide appropriate controls over its travel activities and related
costs. This would involve that travel advances be recorded on the
Authority’s books of account as a receivable against the individual
traveler that would be offset by the amount of the travel voucher
when submitted. Control procedures would include steps to ensure
that travel vouchers are properly documented detailing the nature
and extent of each trip incurred and that travel expenses are
supported by valid travel receipts and documents. In addition, steps
should be implemented for each traveler to submit the correct
travel voucher immediately after each trip.
1E Obtain and review the necessary travel vouchers with the proper
documentation for the three trips discussed in the finding. For any
travel advances and applicable travel costs that are not properly
documented in accordance with the Authority’s travel policy needs
to be refunded the Authority by the traveler. In addition, the
Authority needs to review all travel advances and related vouchers
granted by the Authority and determine if the travel costs were
incurred in conformity the Authority’s travel policy. This review
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needs to include the travel costs and related travel vouchers for all
trips during the last two complete fiscal years and through the
current date.
1F Separate the functions of handling cash receipts from the functions
of recording cash receipt transactions from the same Authority
employee. This would need to be expanded to separate the
functions of establishing and calculating tenant charges from the
functions of maintaining and recording the official Authority tenant
files and records. Also, this would involve the separation of
assessing tenants for tenant caused damages from the function of
collecting monies for such repairs.
We also recommend the Northern Plains Office of Native American
Programs:
1G Verify the corrective action taken by the Authority for
recommendations 1A through 1F after they have been implemented
and to ensure the appropriate controls are in place and functioning
and that the Authority is implementing the policies and procedures
as adopted by the Authority Board; and
1H Maintain the High Risk Designation for the Authority until the
recommendations listed above have been fully implemented.
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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. Management is responsible for establishing effective management controls.
Management controls, in the broadest sense, include the plan of organization, methods and procedures
adopted by management to ensure that its goals are met. Management controls include the processes for
planning, organizing, directing, and controlling program operations. They include systems for measuring,
reporting, and monitoring program performance.
We determined the following Chippewa Cree Housing Authority’s
Management controls
management controls were relevant to our audit objectives:
assessed
• Governing policies and procedures as promulgated by the Authority
Board of Commissioners;
• HUD housing program monies were expended for eligible activities
and costs; and
• Housing program revenues were properly controlled and recorded.
The following audit procedures were used to evaluate the management
Assessment procedures
controls:
• Review of Board minutes and formulated policies and procedures;
• Interviews with Authority and its fee accountant officials;
• Review of Authority cash disbursement records and related files
related to the eligibility use of HUD program funds;
• Review of Authority cash receiving, depositing and recording
records;
• Evaluation of the Authority’s established procedures for implementing
its HUD funded housing programs; and
• Interview with HUD Northern Plains Office of Native American
Programs officials and review of HUD records and files.
A significant weakness exists if management controls do not give
Significant Weaknesses
reasonable assurance that resource use is consistent with laws,
regulations, and policies; that resources are safeguarded against waste,
loss, and misuse; and that reliable data is obtained and maintained, and
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fairly disclosed in reports. Based on our audit, we identified the following
significant weaknesses:
• The Authority used HUD program monies totaling $150,693 to
finance its own separate non-HUD housing activities (Finding);
• Authority travel and related costs were excessive, unsupported
and/or questionable as eligible HUD-funded housing program costs
(Finding);
• Housing units leasing and occupancy were not adequate to ensure
tenants were properly selected, eligibility certified, correctly verified
income and rent computations, and fully executed lease agreements
(Finding);
• The Authority lacked sufficient controls over the receiving, handling,
and recording Authority revenues (Finding); and
• Combined both functions of handling and recording cash receipts
were vested in the same Authority employee and revenues were not
always deposited timely and intact (Finding).
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Follow-up on Prior Audits
This is the first HUD Office of Inspector General for Audit review of activities of the Chippewa Cree
Housing Authority.
However, the Authority has been reviewed and evaluated by HUD Northern Plains Office of Native
American Programs. On December 19, 1996, the Northern Plains Office of Native American Programs
issued a Corrective Action Order and declared the Authority High Risk under Title 24 Code of Federal
Regulations, Part 85. The Corrective Action Order identified the existence of regulatory deficiencies
relating to Title 24 Code of Federal Regulations Part 950.135 and Part 85.20. The Corrective Action
Order stated the Authority:
1) Lacked administrative capability in the area of general financial management, management
systems and housing development;
2) Was in non-compliance in the financial administration of grants,
3) Had not selected housing applicants in accordance with their waiting lists, and
4) Had other management deficiencies that were supported by audits, on-site reviews or other
reliable information.
The Corrective Action Order also noted that the Housing Authority did not:
1) Hold Board Meetings in compliance with its by-laws;
2) Have properly trained and competent personnel at key management positions,
3) Maintain a stable financial position,
4) Maintain an appropriate financial management systems;
5) Convert initial development grant for Low Rent project; and
6) Select participants in accordance with the Mutual Help or Low Rent waiting lists.
In addition, HUD identified five specific management deficiencies at the Authority in the following areas:
1) user fees; 2) budget overruns; 3) tenant accounts receivable; 4) other sources of income; and 5) audit
findings.
During the week of August 30, 1999, staff of the Northern Plains Office of Native American Programs
conducted an on-site monitoring review of the Authority’s Indian Housing Block Grant program funded
under the NAHASDA. Their draft report was submitted to the Authority for comment on November 16,
1999. After receiving the Authority’s comments, the Northern Plains Office of Native American
Programs issued on February 22, 2000 to the Chippewa Cree Tribe their Final Monitoring Review Report
and High Risk Designation for Indian Housing Block Grant on the Authority. The High Risk Designation
had been placed upon the Authority’s 1998 and 1999 Indian Housing Block Grants. Subsequent to the
February 22, 2000 report, HUD notified the Authority that the High Risk Designation would continue for
its subsequent 2000 fiscal year Indian Housing Block Grant.
The High Risk designation was for the Authority’s 1998 and 1999 Indian Housing Block Grants and was
based on the Authority’s independent auditor’s disclaimer of opinion audit report for the 1996 fiscal year.
The disclaimer related to the Authority’s financial statements and compliance with general requirements.
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The Authority was apprised the High Risk determination would continue until the 1998 independent audit
report was received and the auditor issued a unqualified opinion and there were no significant findings
regarding financial management. The audit results would be reviewed by HUD and a determination made
as to whether the High Risk determination would impact the 2000 fiscal year Indian Housing Block Grant
program.
HUD notified the Authority on March 21, 2000 that their Indian Housing Plan submitted for their Indian
Housing Block Grant Program was acceptable. In addition, the letter also continued the High Risk
Determination for the Authority.
Subsequent to the issuance of HUD’s Final Monitoring Review Report and High Risk Designation for
Indian Housing Block Grant, the Authority’s independent public accountant issued their report for the 1998
fiscal year. This report, dated May 27, 1999, contains an unqualified opinion. However, the audit report
identifies the following findings:
• Material weakness identified in the internal control over financial reporting;
• Reportable conditions were identified that were not considered to be material weaknesses in the
internal control over financial reporting; and
• Material weakness were identified in the internal control over major programs;
Findings presented in the audit report related to payroll records, tenant and homebuyer receivables, fixed
assets, year 2000 issues, tenant and homebuyer receipts, and tenant and homebuyer files.
Correspondence in connection with these reports between the Authority and HUD indicate that
improvements are being made in the Authority’s internal controls over its housing operations.
Our audit report augments the HUD and independent auditor reports.
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Appendices
Appendix 1
Schedule of Questioned Costs
Finding Description Amount
1 Ineligible HUD program funding of non-HUD $126,679
housing activities
1 Unsupported, unnecessary or unreasonable $27,139
travel costs
Questioned costs include ineligible costs, unsupported costs, and unnecessary/unreasonable costs:
1. Ineligible costs are those that are questioned because of an alleged violation of a provision of a law,
regulation, contract, grant, cooperative agreement, or other agreement or document governing the
expenditure of funds.
2. Unsupported costs are those whose eligibility cannot be clearly determined during the audit since such
costs were not supported by adequate documentation.
3. Unnecessary costs are those which are not generally recognized as ordinary, prudent, relevant, and/or
necessary within established practices. Unreasonable costs exceed the costs that would be incurred
by the ordinary prudent person in the conduct of a competitive business.
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Appendix 2
Auditee Comments
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Appendix 3
Distribution
Chippewa Cree Housing Authority
Secretary’s Representative, 8AS (2)
Acting Director, Northern Plains Office of Native American Programs, 8API, (2)
Deputy Assistant Secretary for Native American Programs, 8APINW, , Room 4126
Assistant Secretary for Public and Indian Housing, P, Room 4100
Deputy Secretary, SD, Room 10100
Chief of Staff, S, Room 10000
Assistant Secretary for Administration, A, Room 10100
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
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 for Public Affairs, W, Room 10222
Counselor to the Secretary, S, Room 10234
General Counsel, C, Room 10214
Deputy General Counsel, CB, Room 10220
Office of Policy Development and Research, R, Room 8100
Assistant Deputy Secretary for Field Policy and Management, SDF, Room 7106
Director, Office of Department Operations and Coordination, I, Room 2124
Chief Procurement Officer, N, Room 5184
Chief Information Officer, Q, Room 3152
Chief Financial Officer, F, Room 2202
Deputy Chief Financial Officer for Operations, FF, Room 10166
Director, Office of Budget, FO, Room 3270
Director, Enforcement Center, V, 200 Portals Building
Director, Real Estate Assessment Center, X, 1280 Maryland Ave., SW, Suite 800
Departmental Audit Liaison Officer, FM, Room 2206
Headquarters Audit Liaison Officer, Public and Indian Housing, PF, Room P8202
Field Audit Liaison Officer, 6AF, (2)
Director of Scheduling and Advance, AL, Room 10158
Assistant Deputy Secretary for Field Policy and Management, SDF, Room 7108 (2)
Special Assistant to the Deputy Secretary for Program Management, SD, Room 10100
Acquisitions Librarian, Library, AS, Room 8141
Inspector General, G, Room 8256
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 Governmental Reform, 2185 Rayburn Bldg., House of
Representatives, Washington, DC 20515
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Henry A. Waxman, Ranking Member, Committee on Governmental Reform, 2204 Rayburn Bldg., House
of Representatives, Washington, DC 20515
Ms. Cindy Fogleman, 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, NW, Room 2474, Washington, DC 20548 (Attention: Judy England-Joseph )
Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy and Urban Resources,
B373 Rayburn House Office Building, Washington, DC 20515
Steve Redburn, Chief, Housing Branch, Office of Management and Budget, 725 17th Street, NW, Room
9226, New Executive Office Building, Washington, DC 20503
42
Review of Housing Activities and Related Management Controls, Chippewa Cree Housing Authority, Rocky Boy Reservation
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-09-21.
Below is a raw (and likely hideous) rendition of the original report. (PDF)