AUDIT REPORT
NEWPORT RESIDENT COUNCIL, INC.
NEWPORT, RHODE ISLAND
2002-BO-1003
APRIL 30, 2002
OFFICE OF AUDIT, NEW ENGLAND
BOSTON, MASSACHUSETTS
Issue Date
April 30, 2002
Audit Case Number
2002-BO-1003
TO: Donna Ayala, Director, Office of Public Housing, 1APH
FROM: Barry L. Savill, District Inspector General, Office of Audit, 1AGA
SUBJECT: Newport Resident Council, Inc.
Newport, Rhode Island
As requested by your office, we performed an audit of the Newport Resident Council,
Inc.,(NRC). The overall objective of our audit was to determine if the NRC was administering
its federal funds in an efficient, effective and economical manner and in compliance with the
terms of its federal contracts and regulations. The NRC received $195,275 from the Housing
Authority of the City of Newport, Rhode Island through the Comprehensive Grant Program and
Tenant Services Program between August 1, 1999 and January 31, 2001. The NRC also received
$70,000 from the City of Newport, Rhode Island through the Rhode Island Small Cities
Community Development Block Grant for the Employment Readiness Program.
Our audit disclosed the NRC did not establish accountability over these funds. Specifically, the
NRC failed to maintain adequate accounting records and monitoring procedures resulting in
$42,887 in questionable costs. These deficiencies occurred because the NRC Board of Directors
did not effectively manage and account for its federal funds.
Within 60 days, please provide us a status report for each recommendation listing: (1) the corrective
action taken; (2) the proposed corrective action and the date to be completed; or (3) why action is
not considered necessary. Also, please furnish us copies of any correspondence or directives issued
because of this audit.
If you have any questions, please contact our office at (617) 994-8380.
Management Memorandum
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2002-BO-1003 Page ii
Executive Summary
As requested by your office, we performed an audit of the Newport Resident Council, Inc.
(NRC). The overall objective of our audit was to determine if the NRC was administering all
federal funds it received in an efficient, effective and economical manner and in compliance with
the terms of its federal contracts and regulations. The NRC received funds from the Housing
Authority of the City of Newport, Rhode Island (Authority) through the Comprehensive Grant
Program and Tenant Services Program. The NRC also received funds from the City of Newport,
Rhode Island (City) through the Rhode Island Small Cities Community Development Block
Grant for the Employment Readiness Program.
Our audit disclosed the NRC did not establish
Audit Results accountability over all federal funds it received from the
Authority and City, including Comprehensive Grant
Program (CGP), Tenant Services Program and Employment
Readiness Program funds, which as of January 31, 2001
totaled $265,275. Specifically, the NRC failed to maintain
adequate accounting and monitoring records over
Comprehensive Grant Program, Tenant Services Program
and Employment Readiness Program funds provided by the
Authority and City. We also noted $42,887 in questionable
costs. The deficiencies occurred because the NRC Board of
Directors did not effectively manage and account for its
federal funds.
Since the NRC received CGP and Tenant Services Program
funds from the Authority, we recommend that you require
the Authority to ensure that the NRC reimburses the
Authority for all ineligible expenditures made from federal
funds and that appropriate administrative action is taken
against NRC individuals who improperly used federal
funds.
We also recommend that you require the Authority to
ensure that the NRC evaluates the reasonableness and
eligibility of all expenditures charged to the Comprehensive
Grant Program and Tenant Services Program. Lastly, we
recommend that you require the Authority to ensure that the
NRC establishes fiscal accountability and effective
management controls in regards to the use of federal funds.
Page iii 2002-BO-1003
Executive Summary
We discussed the findings in this report with the Authority
Findings and and the NRC staff and Board members during the course of
Recommendations the audit. On February 26, 2002, we provided the
Discussed Authority and NRC a copy of the draft audit report for
comment. We received the NRC’s written response on
March 15, 2002 and the Authority’s response on March 25,
2002. We included their pertinent comments in the Finding
section of this report. The NRC’s full response is included
in Appendix C and the Authority’s full response is included
in Appendix D.
2002-BO-1003 Page iv
Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1. Accountability for Federal Funds Not Established 7
Management Controls 13
Appendices
A Schedule of Questioned Costs 15
B Questionable Credit Card Charges 17
C Questionable Check Disbursements 19
D Auditee Comments Newport Resident Council, Inc. 21
E Auditee Comments – Newport Housing Authority 24
F Distribution 27
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Table of Contents
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2002-BO-1003 Page vi
Introduction
The Newport Resident Council, Inc. (NRC) is an organization of and for residents of the public
housing developments within the Housing Authority of the City of Newport, Rhode Island
(Authority). As of May 17, 2001, the Authority had six developments with 1,096 units and 3,451
residents. The NRC’s mission is to provide programs and services to maximize residents’
dignity, respect, standard of living and quality of life.
The Board of Directors is the governing body of the NRC. Any resident of a development
managed by the Authority may join the NRC. The residents elect the fourteen members of the
Board of Directors, which include the President of the Board and Development Representatives.
The minimum number of Board members allowed is seven. The Board is responsible for
overseeing the operation of the NRC and appointing an Executive Director who runs the day-to-
day operations of the NRC. As of the time of our review, the NRC had no Executive Director
and had effectively ceased operations.
During the period of our review, NRC received funding from the Housing Authority, the City of
Newport, RI and several non-federal sources.
Funding for Newport Resident Council
Newport Housing Authority Tenant
Services Program 1%
Newport Housing City of Newport
Authority Employment
Comprehensive Grant Readiness Program
Program 67% 25%
Non-Federal sources 7%
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Introduction
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2002-BO-1003 Page 2
Introduction
NRC Contracts with the Authority
The Authority used its Comprehensive Grant Program (CGP) to fund a contract with the NRC.
Under this contract NRC would provide services to low-income residents for the period of
August 1,1999 to July 31, 2000. Tasks under this contract included:
Ø outreach and organizing;
Ø computer training;
Ø job development training; and
Ø workshops and seminars on skills training and development.
NRC and the Authority entered into a one-year contract for August 1, 1999 and July 31, 2000 for
$130,000 with an additional $12,133 for the purchase of laptop computers and $3,942 for other
tenant-related services. When this contract expired, on July 31, 2000, the Authority did not enter
into another contract because the Authority was not satisfied with the NRC’s performance.
Although the contract had expired, the Authority agreed to continue funding NRC if the NRC
could: (1) document their expenses and (2) demonstrate their achievement of the specified goals
and objectives stated in the initial contract. Using funding from the Comprehensive Grant
Program and the Tenant Services Program, the Authority provided another $49,200 to the NRC
between August 1, 2000 and January 31, 2001.
NRC also contracts with the City
The City of Newport used its Small Cities Community Development Block Grant to fund a $70,000
contract with the NRC for job training under the Employment Readiness Program. The
Employment Readiness Program exists to fill the gap left by traditional training programs that are
not prepared to address many of the social, economic and educational problems impacting
disadvantaged individuals and their families. NRC was contractually required to assist forty to fifty
residents of the Authority and an additional ten to twenty low-income individuals from subsidized
housing developments in the area. During the contract’s term of August 1, 1999 to July 31, 2000,
NRC would teach various skills to residents such as:
Ø shaking hands in the business world,
Ø being responsible and dependable,
Ø dressing in appropriate business attire,
Ø conducting interviews,
Ø writing a resume,
Ø utilizing a telephone professionally
Ø using a computer
Non federal funding.
NRC received almost $20,000 from non-HUD sources including national non-profit organizations,
state-wide non-profit organizations and local fund raising efforts.
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Introduction
Audit discovers problems
NRC hired an independent public accountant to conduct an audit of its operations. Dated June 30,
2000, the audit report identified operational problems such as:
Ø personal charges made to NRC credit cards,
Ø loans to employees and board members, and the
Ø absence of NRC credit card and travel policies.
In January 2001, a second independent audit was scheduled by the Authority in response to
allegations of credit card abuse by NRC personnel published in local newspapers. The NRC
refused to provide records to the Authority subsequent to July 31, 2000. The NRC believed that the
Authority had no justification for reviewing its records after July 31, 2000 because the contract
between the Authority and the NRC had expired. As a result, the Authority has refused to provide
additional funds to the NRC until an audit is completed.
In February 2001, the Massachusetts Office of Public Housing requested that our office audit the
NRC’s books and records.
The overall objective of our audit was to determine if the
Audit Objectives NRC was administering all federal funds it received in an
efficient, effective and economical manner and in
compliance with the terms of its federal contracts and
regulations.
To accomplish our audit objective, we:
Audit Scope and
Methodology Ø Obtained and reviewed the NRC’s contracts with the
Housing Authority of the City of Newport, Rhode Island
and the City of Newport, Rhode Island, and federal
regulations.
Ø Obtained and reviewed the independent audit report
dated June 30, 2000;
Ø Reviewed the NRC’s financial records of cash receipts
and disbursements;
Ø Selected and reviewed a sample of 119 out of 502 check
disbursements made between August 1999 through
January 2001 to determine whether items were
reasonable and necessary under the contract and were
adequately supported. We determined that a non-
2002-BO-1003 Page 4
Introduction
representational sample was appropriate for testing the
allegations.
Ø Reviewed petty cash account transactions between August
1999 and January 2001 to determine the nature and
reasonableness of expenditures;
Ø Determined whether NRC staff and members of the Board of
Directors have repaid all loans from NRC funds identified
during our audit period;
Ø Reviewed the NRC's credit card policies and procedures to
determine if policies and procedures are reasonable, adequate
and comply with federal regulations governing the funding;
Ø Reviewed all credit card charges between August 1999 and
January 2001 to determine if the charges were reasonable and
necessary for the operation of the NRC and in compliance
with the contracts and federal regulations;
Ø Evaluated the reasonableness and eligibility of all out-of-state
travel costs charged to HUD programs between August 1999
and January 2001;
Ø Inventoried the laptop computer equipment purchased with
HUD funds;
Ø Held discussions with NRC staff, the President of the Board
of Directors, the NRC’s independent auditors, the NRC’s
attorney, and the HUD Massachusetts State Office of Public
Housing staff.
We conducted our audit at the NRC’s office located in Newport,
Rhode Island. Our audit covered the period between August 1,
1999 and January 31, 2001. Where appropriate, the review was
extended to include other periods. Audit work was performed
from February 2001 through March 2001.
Our audit was conducted in accordance with generally accepted
government auditing standards.
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Introduction
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2002-BO-1003 Page 6
Finding 1
Accountability for Federal
Funds Not Established
The Newport Resident Council, Inc. (NRC) did not establish accountability for HUD funds. The
NRC failed to maintain adequate accounting records and failed to perform their contractual
obligation. As a result, the NRC is unable to assure either the Authority or the City that charges to
its programs are reasonable, eligible and effectively utilize limited federal funds. These
deficiencies occurred as a result of the NRC’s Board of Directors’ inability to effectively manage
and account for its federal funds. Between August 1999 and January 2001, NRC incurred
questionable costs of $42,887.
The NRC’s contract with the Authority requires NRC to
Adequate Financial comply with all applicable federal and state financial audit
Management System requirements pertaining to non-profit organizations. The
Required NRC’s contract with the City also requires that the NRC
comply with federal regulations including OMB Circular
A-110 Grants and Agreements with Institutions of Higher
Education, Hospitals, and Other Non-Profit Organizations.
In Subpart C paragraph 21 (b) 2, 3, and 7, OMB Circular A-
110 states that recipients’ financial management systems
shall provide for:
(2) Records that identify adequately the source and
application of funds for federally sponsored activities.
These records shall contain information pertaining to
Federal awards, authorizations, obligations, unobligated
balances, assets, outlays, income, and interest . . .
(3) Effective control over and accountability for all funds,
property, and other assets. Recipients shall adequately
safeguard all such assets and assure that they are used
for authorized purposes . . .
(7) Accounting records including cost accounting records
that are supported by source documentation.
NRC’s accounting records were not accurate because
expenses were not accurately posted to the accounting
records. The NRC received $265,275 in HUD funds and
almost $20,000 from various other non-HUD sources
Page 7 2002-BO-1003
Finding 1
including national non-profit organizations, state-wide non-
profit organizations and local fund raising efforts. Although
the NRC received $285,275 between August 1, 1999 and
January 31, 2001, it expensed $292,945 or $7,670 more than
it received.
Amount
Amount Expensed
Funding Source Funded on Books Difference
Comprehensive Grant Program $191,333 $229,084 ($37,751)
Tenant Services $3,942 $4,911 ($969)
Employment Readiness Program $70,000 $51,513 $18,487
non-federal sources $20,000 $7,437 $12,563
Total $285,275 $292,945 ($7,670)
Between August 1999 and January 2001, NRC charged
$41,938 on their credit cards. During this same period, it
expensed $20,629, posted $13,882 to their Accounts
Payable and did not account for the remaining $7,427.
However, when we manually calculated the amount of
credit card charges not recorded as Accounts Payable
between November 2001 and January 2001, we found that
$7,591 was not recorded. NRC personnel were unable to
reconcile or explain the difference between the $7,427 and
$7,591.
Between August 1999 and January 2001, NRC paid
Questionable Expenditures $42,887 in questionable expenditures. Of this amount
Paid $26,342 represented credit card charges (Appendix B) and
$16,545 represented check disbursements (Appendix C).
OMB Circular A-122, Cost Principles for Non-Profit
Organizations advises that allowable costs must be
reasonable for the performance of the award, allocable to
the award and adequately documented. To determine the
reasonableness of a given cost, consideration shall be given
to whether the cost is of a type generally recognized as
ordinary and necessary for the operation of the organization
or the performance of the award.
2002-BO-1003 Page 8
Finding 1
The $26,342 of questionable credit card charges included
Used Credit Cards for personal expenses of the NRC’s former Executive Director
Personal Expenses such as meals, hotel lodging, flowers, grocery, alcohol, and
jewelry. NRC also made purchases for events such as staff
birthdays, going-away parties, Secretary’s Day, Valentine’s
Day, and the wedding of a relative of a Board member.
There was no supporting documentation available to
evidence that any of the $26,342 in credit card charges were
necessary for the performance of NRC’s federally funded
programs. Attachment A lists these questionable
expenditures.
The $16,545 of questionable disbursements by check
Questionable Check included cash bonuses to the NRC’s former Executive
Disbursements Director, NRC staff members, volunteers, and members of
the Board of Directors; and loans to NRC staff and Board
members. In addition, proper supporting documentation
was not available for services such as cleaning, instructor
fees, and bookkeeping, as well as, trips made by NRC staff,
and meal reimbursements. Attachment B shows a listing of
these questionable expenditures.
Prior to August 2000, the NRC did not have a credit card
Credit Card Policy not in
policy. When the NRC promulgated a credit card policy in
Accordance with Federal
August 2000, it contradicted federal regulations by stating,
Regulations
in part:
Purchases of items for personal use, which are of a non-
business nature, is not allowed without direct
authorization of the Board of Directors or the Executive
Director.
OMB Circular A-122, Attachment B, paragraph 18
specifically states that: costs of goods or services for
personal use of the organization's employees are
unallowable regardless of whether the cost is reported as
taxable income to the employees. NRC’s policy should be
revised to prohibit this practice under all circumstances.
The NRC issued three credit cards: (1) NRC’s former
Accrual of Credit Card Executive Director, (2) President of the Board of Directors,
Finance Charges and (3) the Office Manager. Between August 1999 and
January 2001, $41,938 was charged to these cards. The
unpaid balance in January 2001 totaled $8,055. However,
the NRC bank account as of February 2001 showed only
Page 9 2002-BO-1003
Finding 1
$3,497 in funds available, which is approximately $4,500
less than the credit card balance. With no active funding
sources, the NRC will continue to needlessly incur interest
expenses on the credit cards.
Prior to August 2000, the NRC did not have a travel policy.
Travel Policies Not However, subsequent to August 2000 when NRC
Enforced developed a policy they did not follow or enforce their
policy. Our review disclosed that NRC employees received
travel advances, but did not reconcile actual travel costs
with the advances. As a result, NRC staff used credit cards
to pay travel-related expenditures for which they had
previously received an advance. NRC did not maintain
adequate documentation to identify the traveler, identify the
purpose of the trip, or compute actual expenditures less any
travel advances. Supporting documentation typically
consisted of either a check requisition form or a memo
from the NRC’s former Executive Director regarding the
trip.
NRC’s Board of Directors was aware that the NRC’s
Inadequate Oversight by former Executive Director was using NRC resources for
Board personal expenses. In October 2000, the Board of Directors
discussed the significant amount of personal charges on the
credit cards with the NRC’s former Executive Director and
requested that he sign a repayment agreement. According
to the President of the Board of Directors, the former
Executive Director acknowledged to the Board that he used
the credit cards for personal reasons and he refused to sign
the repayment agreement. Although the Board was aware
of the personal charges and the former Executive Director’s
refusal to sign a repayment agreement, the Board did not
remove the credit cards from the former Executive
Director’s possession until January 2001. Failure to close
the credit card accounts allowed the former Executive
Director to charge an additional $6,880 in questionable
costs after October 2000.
2002-BO-1003 Page 10
Finding 1
As a result of the lack of accountability, the NRC is unable to
Improvements Needed assure the Authority and HUD that its expenditures are
reasonable, eligible, and an effective use of limited Federal
funds. The NRC Board of Directors needs to ensure:
Ø accountability over all Federal funds,
Ø policies and procedures are appropriate, implemented,
and comply with Federal regulations.
Auditee Comments Authority and NRC Comments
As the NRC is funded by HUD through the Authority, both
the Authority and the NRC were given the opportunity to
comment on the report. A complete text of the Authority’s
response is available in Appendix B and a complete text of
the NRC’s response is available in Appendix C.
Both the Authority and the NRC advise that they have
implemented a system to avoid re-occurrence of the
questionable expenditures. Both the NRC and the Authority
believe that individuals should be held accountable for their
actions. Both the Authority and the NRC contend that they
will be unable to determine the eligibility of expenditures
with the available records when professional auditors are
unable to determine eligibility. Both the Authority and NRC
contend that the NRC has no substantial source of funds
other than HUD funds therefore reimbursement from non-
federal funds is not practical.
Additional Comment by the Authority
The Authority noted that it made the request to HUD for an
audit to assist with dealing with stone-walling of the former
Executive Director and it continues to request HUD’s
assistance to impose appropriate sanctions as recommended.
Additional Comment by the NRC
The NRC contends that the Board instructed the employees
to no longer use the credit cards when it learned of
questionable expenditures. The NRC’s response also
Page 11 2002-BO-1003
Finding 1
contends that the Board had no reason to believe its
instructions would not be followed.
OIG Evaluation of The new system to avoid re-occurrence of questionable
Auditee Comments expenditures needs to be evaluated by HUD to ensure
recurrence is avoided. Individuals should be held
accountable for their actions. Expenditures whose eligibility
cannot be proven should be reimbursed to the program.
NHA and NRC should pursue their plan to obtain
reimbursement from individuals. Repayment of remaining
funds should be discussed with HUD.
NRC contends that it did not know that its instructions would
not be followed. The existence of questionable expenditures
gives reason to believe that instructions would not be
followed.
Recommendations We recommend that you require the Authority to:
1A. Require the NRC to reimburse the Authority for all
ineligible costs.
1B. Impose appropriate administrative sanctions against
individuals who improperly used federal funds.
1C. Require the NRC to provide your staff
documentation of the amount, the eligibility and the
reasonableness of all expenditures
1D. Require the Authority to ensure that NRC
establishes fiscal accountability and effective
management controls to assure that Federal funds
are used effectively and efficiently.
1E. Require the NHA to monitor the performance of its
contractors to ensure that all expenditures are
reasonable for the performance of the contract and
accurately reflect expenditures necessary to the
contract.
2002-BO-1003 Page 12
Management Controls
In planning and performing our audit, we considered management controls of the Newport
Resident Council, Inc. (NRC) as specifically related to funding provided by the Housing
Authority of the City of Newport, Rhode Island (Authority) and by the City of Newport, Rhode
Island (City). We evaluated management controls to determine our auditing procedures to be
used, and not to provide assurance on management controls.
Management controls consist of a plan or organization and methods and procedures adopted by
management to ensure 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,
maintained, and fairly disclosed in reports.
We determined the following management controls were
Relevant Management
relevant to our audit objectives:
Controls
Ø Financial controls over program funding
Ø Management controls over program expenditures
Ø Policies and procedures over travel and credit card
usage
A significant weakness exists if management controls do
Assessment Results not give 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, maintained, and fairly
disclosed in financial statements and reports.
Our review identified significant weaknesses at the NRC
Significant Weaknesses including their lack of accountability over HUD funds
received from the Authority and the City. Specific
weaknesses were identified in all of the management control
areas discussed above. These weaknesses are described in
the Finding section of this report.
Page 13 2002-BO-1003
Management Controls
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2002-BO-1003 Page 14
Appendix A
Questioned Costs
Finding 1 Amount
Questionable Disbursements via check, Details in Appendix B $26,342
Questionable Disbursements via credit card, Details in Appendix C $16,545
Total $42,887
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Appendix A
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2001-BO-1003 Page 16
Appendix B
Questionable Credit Card Charges
Category Amounts
Cash Advances $ 9,093
Local Meals 3,925
Local Hotels 1,975
Hotel charges for out-of-state travel (includes movies, phone, parking) 1,689
Department Store Purchases 1,542
Other Purchases 1,158
Meals for out-of-state travel 1,078
Finance Charges/Late Payment Charges/Cash Advance Fees 974
Cash Advances for out-of-state travel (including ATM fees) 921
Jewelry Store Purchases 842
Grocery Store Purchases 701
Transportation costs for out-of-state travel 501
Video Store Purchases 392
Pharmacy Purchases 344
Liquor Store Purchases 303
Merchandise/Department Store Purchases for out-of-state travel 243
Other Purchases for out-of-state travel 207
Music Store Purchases 189
Flower Shop Purchases 81
Toy Purchases 75
Alcoholic Beverages for out-of-state travel 45
Convenience Stores/Gas Station Purchases 34
Gas for out-of-state travel 30
Totals $26,342
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Appendix B
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2002-BO-1003 Page 18
Appendix C
Questionable Check Disbursements
Description Amount
1999 Bonus to Executive Director $ 5,000
Loans to NRC staff and Board Members 2,500
Payments for Services (bookkeeping, cleaning, instructors, landscaping) 2,480
Trips made by NRC staff and food reimbursements 2,070
2000 Christmas bonus to Board Members ($675)and volunteers ($400) 1,075
Payments for volunteer services 760
1999 Christmas bonus to Board Members ($500) and volunteers ($250) 750
1999 Christmas bonus to NRC staff members 700
Flowers 609
2000 Christmas bonus to NRC staff members 450
Charitable contribution 100
Pantyhose 26
NRC staff member parking ticket 25
Total $16,545
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Appendix C
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2002-BO-1003 Page 20
Appendix D
Auditee Comments
Newport Resident Council, Inc.
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Appendix D
2002-BO-1003 Page 22
Appendix D
Page 23 2002-BO-1003
Appendix E
Auditee Comments
Newport Housing Authority
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Appendix E
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Appendix E
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Appendix F
Distribution Outside of HUD
Chairman, Committee on Governmental Affairs, 340 Dirksen Senate Office Building, 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 Oversights 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
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Appendix F
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Newport Resident Council, Inc. Newport, Rhode Island
Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-04-30.
Below is a raw (and likely hideous) rendition of the original report. (PDF)