Table of Contents Issue Date May 31, 2000 Audit Case Number 00-KC-209-1002 TO: Michael A. Williams, Director, Troubled Agency Recovery Center, PB1 FROM: Roger E. Niesen, District Inspector General for Audit, 7AGA SUBJECT: St. Louis Housing Authority Paul Simon Tenant Association Board We have completed an audit of the Tenant Association Board for the Paul Simon Elderly Building. The objective of our audit was to determine if the Board followed proper procedures and fully accounted for its funds. The audit was conducted in response to a citizen’s complaint. We determined that the Board’s officers failed to comply with the requirements governing them. They did not apply sound financial management principles, and as a result could not account for $15,158 in funds they received during the audit period. They also did not perform other duties assigned to them and did not meet individual eligibility requirements to serve on the Board. Therefore, the current officers should be replaced. The St. Louis Housing Authority needs to establish procedures to monitor the Association, and execute a written agreement with the Tenant Association that clearly outlines the Association’s and its Board’s responsibilities. Within 60 days, please provide us, for the recommendations made in this report, a status report on: (1) the corrective action; (2) the proposed corrective action and date to be completed; or (3) why action is considered unnecessary. Also, please provide us copies of any correspondence or directives issued because of the audit. Should you or your staff have any questions, please contact me at (913) 551-5870. Table of Contents Management Memorandum THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page ii Table of Contents Executive Summary We completed an audit of the Tenant Association Board for the Paul Simon Elderly Building. The objective of our audit was to determine if the Board followed proper procedures and if it fully accounted for its funds. The audit was conducted in response to a citizen’s complaint. We concluded that the Board’s officers failed to comply with the requirements governing them. They did not apply sound financial management principles, and as a result could not account for $15,158 in funds they received during the audit period. They also did not perform other duties assigned to them and did not meet individual eligibility requirements to serve on the Board. Therefore, the current officers should be replaced. Additionally, the St. Louis Housing Authority needs to establish procedures to monitor the Association, and execute a written agreement with the Tenant Association that clearly outlines the Association’s and its Board’s responsibilities. The Tenant Association Board for the Paul Simon Elderly The Board Failed To Meet Building did not comply with the requirements for Its Requirements performing their duties or properly conducting themselves. The officers failed to follow HUD’s requirements, the Association’s by-laws, the Code of Conduct, or their dwelling leases. They did not manage their funds, document their meetings, or meet individual eligibility requirements. These shortcomings resulted from the Board’s incompetence. The problems went undetected because the St. Louis Housing Authority did not have a process to oversee or monitor the Association. In addition, the Authority did not enter into a written agreement with the Tenant Association. A written agreement should have required the Board to provide an accounting for the Association’s funds to the Authority. As a result, HUD, the Authority, and the Paul Simon tenants have no assurance that $15,158 was expended appropriately. We recommend that the Director, Troubled Agency Recommendations Recovery Center, take administrative action against the Board members. Additionally, the Director should ensure the St. Louis Housing Authority withdraws its recognition of the current Board and takes steps to replace them. Further, the Housing Authority should execute a written agreement with the Tenant Association, assist them in implementing an accounting system with effective controls, develop and implement procedures to monitor the Tenant Association, and assess the feasibility of recouping lost funds in a civil legal action. Page iii 00-KC-209-1002 Table of Contents Executive Summary We held exit conferences and provided our draft finding to the Finance Director of the St. Louis Housing Authority and to the officers of the Paul Simon Tenant Association Board on April 20, 2000. We received written comments from the Corporate Council for the Housing Authority on May 11, 2000 and from the Tenant Board on May 15, 2000. We considered the comments in preparing our final report and incorporated them into the finding as appropriate. 00-KC-209-1002 Page iv Table of Contents Table of Contents Management Memorandum i Executive Summary iii Introduction 1 Finding Officers Failed To Properly Account For Funds 3 Management Controls 15 Follow Up On Prior Audits 17 Appendices A Schedule of Questioned Costs 19 B Auditee Comments 21 C Distribution 49 Page v 00-KC-209-1002 Table of Contents THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page vi Table of Contents Introduction We received a citizen complaint that the Tenant Association Board for the Paul Simon Elderly Building had not followed proper procedures nor fully accounted for its funds since the Board took office in 1995. In response to this complaint, we audited the Association. Paul Simon is a public housing high-rise located at 1241 Hickory Street in St. Louis, Missouri. The Tenant Association Board qualifies as a resident council. According to HUD’s regulations, the role of a resident council is to improve the quality of life and resident satisfaction and participate in self- help initiatives to enable residents to create a positive living environment for families in public housing. The current Tenant Association Board consists of four members: a President, Vice President, and Treasurer, who were elected to the Board in the October 1995 and re-elected in October 1998, and a Secretary who was elected to the Board for the first time in October 1998. The original Secretary moved and her replacement passed away. In December 1995 and 1998 the officers were sworn in as applicable. The Tenant Association Board elected in October 1995 opened a bank account in November 1995; therefore, we began our review at that point. Our audit objective was to determine if the Paul Simon Audit Objectives Elderly Building Tenant Association Board followed proper procedures and fully accounted for its funds. We performed our on-site work in October 1999 and March Audit Scope and through April 2000 to determine whether the Tenant Methodology Association complied with applicable regulations related to the Board and its financial management. We interviewed the complainant, the Tenant Association Board, St. Louis Housing Authority staff, and HUD staff. We analyzed documents from the Tenant Association, their bank, and their vending and laundry companies, including bank statements and check copies, receipts, Board meeting documents, and correspondence. We also analyzed corresponding documents at the St. Louis Housing Authority. The audit covered the period from November 1995 through February 2000. We conducted the audit in accordance with generally accepted government auditing standards. We provided a copy of our draft finding to the Executive Director and Finance Director of the St. Louis Housing Authority. We also provided the draft finding to each Board officer of the Paul Simon Tenant Association. Page 1 00-KC-209-1002 Table of Contents Introduction THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page 2 Table of Contents Finding Officers Failed To Properly Account For Funds The officers of the Tenant Association Board for the Paul Simon Elderly Building did not comply with the requirements for performing their duties or properly conducting themselves. The officers did not follow HUD’s requirements, the Association’s by-laws, the Code of Conduct, or their dwelling leases. They did not properly manage funds, document their meetings, or meet individual eligibility requirements. These shortcomings resulted from the Board’s incompetence, and went undetected because the St. Louis Housing Authority did not have a process to oversee or monitor the Association. In addition, the Authority did not enter into a written agreement with the Tenant Association. A written agreement should have required the Board to provide an accounting for the Association’s funds to the Authority. As a result, the Board was unable to account for expenditures of $15,158, and HUD, the Authority, and Paul Simon tenants have no assurance the funds were appropriately used. 24 CFR 964, Tenant Participation and Tenant Opportunities in HUD Regulations Public Housing, says a resident council may only receive funding from a housing authority under a written agreement between the two parties, which obligates the resident council to account to the housing authority for the use of the funds. The CFR also dictates that agreements on the use of community space for resident activities should be put in a written Memorandum of Understanding. In addition, 24 CFR Part 85 requires all subgrantees to keep source documentation and maintain effective control and accountability. This part also requires grantees to monitor the subgrantees to assure compliance. 24 CFR 964 also requires that tenants serving on the resident council board meet the requirements described in the by-laws and comply with their leases. If a resident council fails to satisfy HUD minimum standards for fair and frequent elections, or fails to follow its own election procedures as adopted, HUD shall require the housing authority to withdraw recognition of the council and withhold resident services funds as well as funds provided in conjunction with services rendered for resident participation in public housing. The by-laws adopted by the Tenant Association in July 1995 Tenant Association require the Treasurer to keep financial records for the board Requirements and submit written itemized reports to the board at least once a month. The Secretary is to take minutes and keep records of all Board meetings. All expenditures over $100 must be authorized in advance by the Board, all Association funds shall Page 3 00-KC-209-1002 Table of Contents Finding be deposited in the Board’s bank account, and checks are to be signed by 2 officers. The by-laws provide that recognition shall be withdrawn from board members when it is proven that the by-laws, the Code of Conduct, or the dwelling lease have been violated. The Code of Conduct applicable to the Tenant Board is the Tenant Affairs Board Tenant Management Corporation Tenant Association Code of Conduct revised June 1993. It requires Board members to accurately reflect the sentiments of the residents they represent, and be accountable and responsible to them. The Board members are to conduct monthly meetings and put the meetings’ highlights in report form. The reports are to include agendas, minutes, attendance lists, meeting notification letters, and be submitted to the Board of Commissioners and the Tenant Affairs Board monthly. The Code also requires Board members to report correct income at all times. It says Board members are responsible to make certain that failure to perform in the above manner by any Board member will be reported in writing to the Board of Commissioners and the Tenant Affairs Board. In the event of a violation by any Board Member of the Code of Conduct, the St. Louis Housing Authority and the Tenant Affairs Board shall immediately withdraw recognition of the Board member. The Code of Conduct stipulates that unless a waiver has been granted, it is a conflict of interest for a Board member to be an employee of the St. Louis Housing Authority. The St. Louis Housing Authority dwelling lease provides for a "One Strike You’re Out" policy regarding a tenant’s drug use, and prohibits consumption of alcohol in public areas. The lease also contains a provision that residents must report in writing any change in income within 30 days. Board members did not comply with requirements, or properly The Board Did Not Meet perform their duties. The members violated HUD’s Requirements regulations, the Association’s by-laws, their dwelling lease agreements, and the Code of Conduct. The Board members did not fully account for the Tenant Association’s funds, and did not produce monthly board meeting minutes, resolutions, or treasurer’s reports. The Board also allowed the Association’s corporate status to lapse, did not maintain a checking account, did not obtain advance 00-KC-209-1002 Page 4 Table of Contents Finding authorization for all expenditures over $100, and did not deposit all funds in the Tenant Association’s bank account. The Association received funds from the St. Louis Housing Funds Were Not Authority. It received a $3 allowance per occupied unit Accounted For annually, and a one time $1,000 payment for an arts and crafts program. Further, the Authority provided $210 a month to cover operation and maintenance of laundry facilities. The Association also received commission payments directly from a vending machine company and a laundry company. In addition, the tenants paid the Association directly for activities it sponsored for them. The following table shows the total amount collected and expended during the audit period: Date Description Amount November 1995 Initial Bank Deposit $828 December 1995- Add: Income Received $30,140 February 2000 February 2000 Less: Ending Bank Balance $3,089 Total Amount Expended $27,879 The Board provided evidence of expenditures totaling $12,721 between November 1995 and February 2000, leaving $15,158 unaccounted for. More than half the receipts were for purchases from grocery stores, convenience stores, restaurants and gas stations. The Board said these were purchases of prizes and refreshments for bingo games, tenant parties, holiday meals and gifts, and gas for the vehicle used to do the shopping. The documentation also included evidence that the Board spent $4,450 to take tenants on trips to casinos. The tenants contributed $4,220 toward the trips. The remaining receipts were for pool table supplies, laundry attendant stipends, laundry room insurance, and membership fees. The Board was unable to provide documentation to support the $15,158 that was not accounted for. Their only explanation was that they are poor record keepers. The Authority required the Association to prepare a budget for the laundry costs; however, there was no budget in the Association’s files. The receipts are not sufficient evidence that all items purchased were used for the purposes described by the Board. For example, we observed that in a five day period, the Board Page 5 00-KC-209-1002 Table of Contents Finding made six trips to the grocery store to make purchases totaling $289. Included in the receipts were purchases of medicine, cigarettes, and alcohol. When we asked the Board about these purchases, the Board indicated the purchases were included by mistake. However, this statement contradicts the statement the Board made when they provided us the receipts. They said the receipts were all purchases for the Paul Simon tenants, and no personal purchases were made with the Tenant Association’s funds. We did not include the clearly unacceptable purchases when we totaled the receipts to arrive at the $12,721 figure that was supported. The Board is required to be accountable to the tenants it represents; however, the tenants have no assurance that $15,158 in funds was expended in furtherance of the Association’s objectives. The Board also did not have required documentation in Meetings Were Not support of monthly meetings. The Board’s own by-laws Documented require it to maintain documentation such as minutes, agendas, attendance lists, and meeting notifications. In the 52 month period reviewed, the Board only had 2 sets of minutes, 14 sign- in sheets, 1 treasurer’s report, and 3 agenda sheets. The Board could not adequately explain why the required documentation was not maintained. The Board also failed to maintain a checking account, deposit Basic Business all its funds in a bank, and obtain advance authorization for all Requirements Were Not purchases over $100. The Board said they were unable to Followed open a checking account because the bank required corporate papers. We found the corporation had been administratively dissolved by the Secretary of State for failure to file required reports. The Association had a savings account; however, the Board did not deposit all funds in the bank. Instead, funds were held in anticipation of upcoming purchases. The Board said it was not aware advanced approval was required for all purchases over $100. Good internal controls require an organization to have a checking account so purchases can be made using checks in lieu of cash. In addition, good controls require all cash receipts and disbursements to flow through a bank account to maintain accountability. If proper controls had been in place, the Association would not have lost $280 when its office was burglarized in July 1998. The Board did not establish: internal controls for effective The Authority Did Not control and accountability of funds; a checking account; or an Detect The Problem accounting system to track income and expenses and reconcile 00-KC-209-1002 Page 6 Table of Contents Finding its sources and applications of funds. This situation was not detected by the Authority because it did not have a process to oversee or review the Association. The Authority’s Resident Initiatives office’s role was to facilitate and assist the Board as requested. The Board submitted a budget to the Authority in 1999, but did not expend the Association’s funds in accordance with the budget. It budgeted for a copy machine and office supplies, but did not buy the copy machine because it was unable to purchase one at the allocated price. Instead, the Board reported that it used the funds allocated for a copy machine for office supplies. However, none of the receipts were for office supplies. The Authority did not audit the expenditures to ensure they were for budgeted items and did not have a written agreement that should have required the Tenant Association to account for its expenditures of funds. The Authority’s Finance Director said she was not aware of the requirement to have a written agreement with the Association. Because a written agreement was not developed, the Authority’s and Association’s responsibilities were not defined. Our review of the Paul Simon Tenant Association brought these weaknesses to the attention of the St. Louis Housing Authority. In April 2000, the Authority began taking steps to require all tenant associations to submit financial documents for the prior year, and a current year budget. The Authority said it plans to review the documents on a sample basis. In addition to the Board’s overall failure to perform its duties, Officers Are Not Eligible several Board members violated requirements that should have To Serve On The Board been grounds for, at a minimum, removal from the Board. One Board member admitted to smoking drugs in her unit, and though this statement was witnessed by other Board members and put in writing, she remained on the Board and was not evicted. The Board members who witnessed the statement said they reported the problem to the St. Louis Housing Authority and expected the Authority to initiate a hearing. However, the Authority’s Building Manager who should have acted on the problem left her job, and her replacement was not aware of the situation until we brought it to her attention. Several of the Board members held positions for which they were compensated by the Housing Authority while serving on the Board. One Board member was a full-time employee of the Housing Authority while also on the Board. These Page 7 00-KC-209-1002 Table of Contents Finding positions were conflicts of interest according to the Tenant Association’s own Code of Conduct. Further, one Board member did not timely report an increase in income. Proper reporting of income is required by the dwelling lease. The Association’s Code of Conduct and by-laws require Board members to be removed if they do not fulfill the terms of their lease agreement. In summary, the Paul Simon Tenant Association Board failed to properly account for the funds entrusted to it, and did not follow its own or HUD’s requirements. As a result, HUD lacks assurance the Association met its objectives and benefited the tenants it was created to help. Auditee Comments Excerpts from the Paul Simon Tenant Association Board’s comments on our draft finding follow. Appendix B, page 23, contains the complete text of the comments. The Paul Simon Tenant Association Board prepared a list of expenditures from 1995 through 2000 totaling $25,233. The Board said they have never used any money for their own personal use and although they do not have receipts and records, all funds were used for the residents of Paul Simon. OIG Evaluation of The list that the Tenant Association submitted was not Auditee Comments accompanied by supporting documentation. When we performed our audit, we examined all documentation in the Tenant Association’s files and found support for expenses that totaled $12,721. HUD regulations require source documentation be maintained to support all expenditures. The Tenant Association Board said no money from the Tenant Auditee Comments Association was used to provide trips to gambling casinos, and records were kept of who paid. OIG Evaluation of We did not question the expenses for the gambling trips since the difference between the amount collected from tenants and Auditee Comments the amount spent was not significant. We included the 00-KC-209-1002 Page 8 Table of Contents Finding expenses in our analysis because we also included the associated income collected from the tenants for the trips. The Paul Simon Board said the residents played bingo once a Auditee Comments week until mid 1999 when they began playing twice a week. Residents were charged 25 cents per board only at the second session of bingo each week. The Tenant Association purchased all prizes for bingo and paid a caller $5 per session. OIG Evaluation of The 25 cent charge per board at the second session of bingo each week and the caller fees were not disclosed to us during Auditee Comments our audit. The Tenant Association did not have records to support these payments and receipts and they did not provide any with their comments. Our analysis only included information that was supported by documentation. HUD requires Tenant Associations to maintain documentation to support their income and expenses. Auditee Comments The Paul Simon Tenant Association Board said attendance sheets, notices of tenant meetings, and agendas were kept in a folder in a file cabinet in the office. When the office was burglarized, the folder came up missing. Also, during their tenure the Board had 3 secretaries: Two moved and one is deceased. Some of the records kept by the secretaries were not retrieved. OIG Evaluation of The police report filed subsequent to the break-in reported a Auditee Comments theft of cash. The report quotes the President as saying, “There was nothing else inside the office or the filing cabinet disturbed.” When we discussed the lack of records with the Board during the audit, they said the current Secretary does not prepare minutes, and they did not think the prior Secretary prepared them either. The Code of Conduct requires the Board to submit records to the Board of Commissioners and the city-wide Tenant Board monthly. We determined the records were not being submitted. Auditee Comments The Tenant Association said they were unable to open a checking account without their corporate papers, so they opened a savings account to which they deposited funds and Page 9 00-KC-209-1002 Table of Contents Finding then made withdrawals. They attempted to obtain their corporate papers, but were unable to despite contacts with the Secretary of State, the Housing Authority, and an attorney. OIG Evaluation of Our review of records disclosed that the Board had corporate Auditee Comments status from 1995 until 1998 when its corporate status lapsed for failure to file an annual report. Their attempts to contact the Secretary of State’s office did not take place until 1998. The Board opened a savings account in 1995 but did not always deposit all funds to its account as required by its by- laws. The Board did not open a checking account; therefore, its requirement that checks be signed by 2 officers was not followed. Auditee Comments The Tenant Association Board said the Secretary’s drug usage was reported to the Building Manager and her successor, the city-wide Tenant Board President, and the Housing Authority. Action was not taken because concerned parties did not believe there was adequate proof. The President also said she was told by the then city-wide Tenant Board President and the Housing Authority Executive Director that there was no conflict of interest between her employment at the Housing Authority and her position on the Board. Also, the next Executive Director told her it was a conflict for her to work in the building where she lived, but did not say there was a problem with her being a member of the Board. She further said she took advantage of payroll deduction for her rent while employed by the Housing Authority, and was never delinquent on her rent. She reported changes in her pay to the Manager by providing a Personnel Transaction form. OIG Evaluation of We agree that the President was under a payroll deduction plan for her rent. We determined the late payments were not her Auditee Comments fault and have deleted the reference to late payments from our finding. The tenant files contained documentation supporting the other statements in our report. The Secretary’s file contained an oral admission of drug usage that was witnessed by three individuals who signed a document stating such. Drug usage is a violation of a tenant’s lease. We determined action was not taken by the Authority due to an oversight resulting 00-KC-209-1002 Page 10 Table of Contents Finding from a change in the Building Manager position. The President’s file contained documentation of some reported income changes. However, all pay raises given by the Housing Authority were not reported in the interim between annual recertifications. The Tenant Association’s by-laws provide that recognition shall be withdrawn from the Board members when it has been proven that the by-laws, Code of Conduct, or dwelling lease have been violated. The Tenant Association Board said the Housing Authority and Auditee Comments the city-wide Tenant Board made arrangements for all tenant elections and also verified eligibility. The Board also said they realized their mistakes and will open a checking account and keep proper records given proper guidance. OIG Evaluation of Although the Board members’ eligibility to serve was verified prior to their election, the Board members acted contrary to Auditee Comments their by-laws, Code of Conduct, and dwelling lease while in office. HUD regulations require Board members to meet the requirements described in the by-laws and comply with their leases. Since the Board members acted contrary to these requirements, they are not eligible to continue to serve on the Board. Auditee Comments Excerpts from the St. Louis Housing Authority’s comments on our draft finding follow. Appendix B, page 21, contains the complete text of the comments. The Housing Authority expressed its concern about the apparent irregularities in the Tenant Association’s conduct. The Authority said it could withdraw recognition of the entire current board, forcing the residents of the Paul Simon Development to elect a new tenant board. The Authority is currently in the process of developing Memorandums of Agreement with each tenant board/association, requiring the tenant groups to submit to the Authority detailed budgets and documentation regarding expenditures. The Authority will also require the tenant groups to publish periodic reports to their respective resident communities regarding budgets and expenditures. Page 11 00-KC-209-1002 Table of Contents Finding The Authority indicated that the by-laws for the Tenant Affairs Board of St. Louis, Missouri provide that the resident manager or management agent from each development serve as a non- voting member for their respective subordinate local board. The Authority said it should insist on enforcement of this provision in the future. This will serve to dismantle the wall which exists between the tenant associations and the Authority, as the City Wide Board would serve as a vehicle for management agents to work with the representatives from the various tenant associations. The Housing Authority believed our references to the Code of Conduct were unclear in some instances. The Authority said the draft finding inferred it was responsible for enforcement of the Tenant Association’s Code of Conduct. OIG Evaluation of The Housing Authority’s planned actions described in its’ response, when implemented, should help correct most of the Auditee Comments problems we identified. However, the Authority needs to replace the Paul Simon Board with individuals who meet eligibility requirements and are trained to serve in the respective positions. The Authority needs to perform monitoring to verify that expenditures are appropriate and supported by the budget. In addition, the Housing Authority should require the Tenant Association to implement an accounting system and effective controls that include the use of a checking account. Further, we recommend the Housing Authority assess the feasibility to recoup lost funds in a civil action. We adjusted our finding to clarify our reference to the Code of Conduct. We agree it is the Board members’ responsibility to adhere to their Code of Conduct, including the conflict of interest clause. However, we believe the written agreement between the Housing Authority and the Tenant Association should integrate all the significant requirements for Tenant Associations, including the Association’s own policies and procedures. It is the Housing Authority’s responsibility to enforce the terms of the written agreement. 00-KC-209-1002 Page 12 Table of Contents Finding Recommendations We recommend the Director, Troubled Agency Recovery Center: 1A. Takes appropriate administrative action against the Association’s Board members. 1B. Ensures the St. Louis Housing Authority takes steps to replace the Board. 1C. Ensures the Housing Authority executes a written agreement with the Tenant Association that clearly outlines the Association’s and its Board’s responsibilities. ID. Ensures the Housing Authority requires the Tenant Association to implement an accounting system with effective controls. The controls should include the use of a checking account and maintenance of sufficient source documentation for all transactions. 1E. Ensures the Housing Authority develops and implements procedures to monitor the Tenant Association. 1F. Ensures the Housing Authority assesses the feasibility to recoup lost funds in a civil action. Page 13 00-KC-209-1002 Table of Contents Finding THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page 14 Table of Contents Management Controls In planning and performing our audit, we considered the management controls of the Paul Simon Tenant Association in order to determine our auditing procedures, not to provide assurance on the controls. Management controls 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 the systems for measuring, reporting, and monitoring program performance. We determined the following management control was relevant Relevant Management to our audit objectives: Controls · Assuring effective financial management. We assessed the relevant control identified above. It is a significant weakness if management controls do not provide reasonable assurance that the process for planning, organizing, directing, and controlling program operations will meet an organization’s objectives. Based on our review, we believe the following item is a Significant Weaknesses significant weakness: · The Tenant Association did not implement financial management controls (see Finding). Page 15 00-KC-209-1002 Table of Contents Management Controls THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page 16 Table of Contents Follow Up On Prior Audits This is the first audit of the Paul Simon Tenant Association performed by the Office of Inspector General. Page 17 00-KC-209-1002 Table of Contents Follow Up On Prior Audits THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page 18 Table of Contents Appendix A Schedule Of Questioned Costs Type of Questioned costs Issue Ineligible 1/ Unsupported 2/ Funds unaccounted for $15,158.47 1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity that the auditor believes are not allowable by law, contract or Federal, State or local policies or regulations. 2/ Unsupported costs are costs charged to a HUD-financed or HUD-insured program or activity and eligibility cannot be determined at the time of audit. The costs are not supported by adequate documentation or there is a need for a legal or administrative determination on the eligibility of the costs. Unsupported costs require a future decision by HUD program officials. This decision, in addition to obtaining supporting documentation, might involve a legal interpretation or clarification of Departmental policies and procedures. Page 19 00-KC-209-1002 Table of Contents Appendix A THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page 20 Table of Contents Appendix B Auditee Comments Page 21 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 22 Table of Contents Appendix B Page 23 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 24 Table of Contents Appendix B Page 25 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 26 Table of Contents Appendix B Page 27 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 28 Table of Contents Appendix B Page 29 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 30 Table of Contents Appendix B Page 31 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 32 Table of Contents Appendix B Page 33 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 34 Table of Contents Appendix B Page 35 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 36 Table of Contents Appendix B Page 37 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 38 Table of Contents Appendix B Page 39 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 40 Table of Contents Appendix B Page 41 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 42 Table of Contents Appendix B Page 43 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 44 Table of Contents Appendix B Page 45 00-KC-209-1002 Table of Contents Appendix B 00-KC-209-1002 Page 46 Table of Contents Appendix B Page 47 00-KC-209-1002 Table of Contents Appendix B THIS PAGE LEFT BLANK INTENTIONALLY 00-KC-209-1002 Page 48 Table of Contents Appendix C Distribution Deputy Secretary, SD (Room 10100) Chief of Staff, S (Room 10000) Special Assistant to the Deputy Secretary for Project Management, SD (Room 10100) Acting Assistant Secretary for Administration, S (Room 10110) Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120) Senior Advisor to the Secretary, Office of Public Affairs, S (Room 10132) Director of Scheduling and Advance, AL (Room 10158) Counselor to the Secretary, S (Room 10234) Deputy Chief of Staff, S (Room 10226) Deputy Chief of Staff for Operations, S (Room 10226) Deputy Chief of Staff for Programs and Policy, S (Room 10226) Deputy Assistant Secretary for Public Affairs, W (Room 10222) Special Assistant for Inter-Faith Community Outreach, S (Room 10222) Executive Officer for Administrative Operations and Management, S (Room 10220) General Counsel, C (Room 10214) Director, Office of Federal Housing Enterprise Oversight, O Assistant Secretary for Housing/Federal Housing Commissioner, H (Room 9100) Office of Policy Development and Research, R (Room 8100) Assistant Secretary for Community Planning and Development, D (Room 7100) Government National Mortgage Association, T (Room 6100) Assistant Secretary for Fair Housing and Equal Opportunity, E ( Room 5100) Chief Procurement Officer, N (Room 3152) Assistant Secretary for Public and Indian Housing, P (Room 4100) Chief Information Officer, Q (Room 3152) Director, Office of Departmental Operations and Coordination, I (Room 2124) Chief Financial Officer, F (Room 2202) Director, Enforcement Center, V (200 Portals Building) Director, Real Estate Assessment Center, X (1280 Maryland Avenue, SW, Suite 800) Director, Office of Multifamily Assistance Restructuring, Y (4000 Portals Building) Secretary’s Representative, Great Plains, 7AS Senior Community Builder, Iowa State Office Senior Community Builder, Omaha Area Office Senior Community Builder, St. Louis Director, Office of Public Housing, 7APH Section 8 Financial Management Center, PCFD St. Louis Public Housing Program Center, Coordinator, 7EPH Deputy Chief Financial Officer for Finance, FF (Room 2202) Director, Office of Budget, FO (Room 3270) Headquarters Audit Liaison Officer, HQC Deputy Secretary, Special Assistant, SD (Room 10126) Public and Indian Housing, PF (Room 5156) Primary Field Audit Liaison Officer, 6AF Acquisitions Librarian, Library, AS, (Room 8141) Chairman, Committee on Governmental Affairs, 340 Dirksen Senate Office Building, Page 49 00-KC-209-1002 Table of Contents Appendix B United States Senate, Washington, DC, 20510 Ranking Member, Committee on Governmental Affairs, 706 Hart Senate Office Building, United States Senate, Washington, DC 20510 Chairman, Committee on Government Reform, 2185 Rayburn Building, House of Representatives, Washington, DC 20515 Ranking Member, Committee on Government Reform, 2204 Rayburn Building, House of Representatives, Washington, DC 20515 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 Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human Resources, B373 Rayburn House Office Building, Washington, DC 20515 Chief, Housing Branch, Office of Management & Budget, 725 17th Street, NW, Room 9226, New Executive Office Building, Washington, DC 20503 00-KC-209-1002 Page 50 Table of Contents
St. Louis Housing Authority Paul Simon Tenant Association Board
Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-05-31.
Below is a raw (and likely hideous) rendition of the original report. (PDF)