oversight

Ypsilanti Housing Commission, Ypsilanti, Michigan

Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-03-26.

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

              AUDIT REPORT




          YPSILANTI HOUSING COMMISSION
       SAFEGUARDING MONETARY ASSETS AND
                    INVENTORY

              YPSILANTI, MICHIGAN

                   2002-CH-1001

                  March 26, 2002


              OFFICE OF AUDIT, MIDWEST
                  CHICAGO, ILLINOIS



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                                                                   Issue Date
                                                                      March 26, 2002
                                                                  Audit Case Number
                                                                      2002-CH-1001




TO:            Joann L. Adams, Director of Public Housing Hub, Michigan State Office


FROM:          Heath Wolfe, District Inspector General for Audit, Midwest

SUBJECT:       Ypsilanti Housing Commission
               Safeguarding Monetary Assets And Inventory
               Ypsilanti, Michigan

We completed an audit of the Ypsilanti Housing Commission. The audit was conducted based
on the Michigan State Office of Public Housing Hub’s concerns about the Housing
Commission’s controls over monetary assets and inventory. The primary objective of our audit
was to determine whether the Housing Commission had sufficient controls for safeguarding cash
and other monetary assets and inventory.

We found that the Housing Commission’s controls over cash and other monetary assets and
inventory were weak. Specifically, the Housing Commission: (1) improperly claimed $98,466 in
operating subsidy since the Commission did not adjust its subsidy claims for long-term vacant
units and inflated the number of occupied units claimed; (2) failed to maintain an acceptable
level of occupancy that resulted in the Commission losing an estimated $157,286 in rental
income; and (3) did not implement procedures and controls to safeguard its cash and other
monetary assets against possible waste, loss, and misuse. Procedures and controls were lacking
over: cash receipts and deposits; disbursements; equipment; procurement; and financial and
administrative processes.

Within 60 days, please provide us, for each recommendation made in this report, a status report on:
(1) the corrective action taken; (2) the proposed corrective action and the date to be completed; or
(3) why action is considered unnecessary. Also, please provide us copies of any correspondence or
directives issued because of the audit.

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




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Executive Summary
We completed an audit of the Ypsilanti Housing Commission. The primary objective of our audit
was to determine whether the Housing Commission had sufficient controls for safeguarding cash
and other monetary assets and inventory. The audit was conducted based on the Michigan State
Office of Public Housing Hub’s concerns about the Housing Commission’s controls over monetary
assets and inventory.

The Housing Commission’s controls over cash and other monetary assets and inventory were weak.
The Commission: inappropriately claimed $98,466 in operating subsidy since the Commission did
not adjust its subsidy claims for long-term vacant units and inflated the number of occupied units
claimed; did not maintain an acceptable level of occupancy that resulted in the Commission losing
an estimated $157,286 in rental income; and failed to implement procedures and controls to
safeguard its cash and other monetary assets against possible waste, loss, and misuse. Procedures
and controls were lacking over: cash receipts and deposits; disbursements; equipment;
procurement; and financial and administrative processes.



                                     The Housing Commission improperly claimed an inflated
 The Commission’s                    operating subsidy. The Commission did not adjust its
 Operating Subsidy Was               subsidy claims for long-term vacant units and it inflated the
 Inflated                            number of occupied units claimed.             Because the
                                     Commission improperly claimed an inflated operating
                                     subsidy, HUD paid $98,466 worth of excess operating
                                     subsidies to the Commission from July 1, 1996 to June 30,
                                     2001.

                                     The Housing Commission did not maintain an acceptable
 The Commission Needs                level of occupancy.     Despite a waiting list of 131
 To Reduce High Vacancy              applicants, the Commission’s vacancy rate at December 31,
 Rates                               2000 was 17.5 percent. As a result, the Commission lost an
                                     estimated $157,286 worth of rental income from January 1,
                                     1997 to December 31, 2000 because of its high vacancy
                                     rates.

                                     The Housing Commission did not safeguard its cash and
 Controls For Safeguarding           other monetary assets against possible waste, loss, and
 Assets Need                         misuse. Management controls over cash receipts, deposits,
 Strengthening                       disbursements, equipment, procurement, and financial and
                                     administrative processes were weak. Similar weaknesses
                                     were identified in previous OIG audits of the Commission
                                     for almost 20 years.

                                     We recommend that HUD’s Director of the Michigan State
 Recommendations                     Office of Public Housing Hub assure that the Housing

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               Commission implements controls to correct the weaknesses
               cited in this report.

               We presented our draft findings to the Housing
               Commission’s Executive Director and HUD’s staff during
               the audit. We held an exit conference with the Commission
               on January 29, 2002. The Commission agreed to implement
               corrective action to improve its controls over operating
               subsidy requests and take action to reduce its high vacancy
               rates.    The Commission disagreed that controls for
               safeguarding assets need strengthening.

               We included paraphrased excerpts of the Housing
               Commission’s comments with each finding. The complete
               text of the comments is in Appendix B.




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Management Memorandum                                                           i



Executive Summary                                                          iii




Introduction                                                                1



Findings

1     The Commission’s Operating Subsidy Was Inflated                       3

2     The Commission Needs To Reduce High Vacancy Rates                     9

3     Controls For Safeguarding Assets Need Strengthening                  15



Management Controls                                                        27



Follow Up On Prior Audits                                                  31



Appendices

    A Schedule of Questioned Costs                                         33

    B Auditee Comments                                                     35

    C Distribution                                                         47


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Introduction
The Ypsilanti Housing Commission was established under State of Michigan law. The Housing
Commission contracts with HUD to provide low and moderate-income persons with safe and
sanitary housing through rent subsidies. A five member Board of Commissioners governs the
Commission. The President of the Board is Macheryl Jones. The Commission’s Executive
Director is Janine Scott. The Commission's books and records are located at 601 Armstrong Drive,
Ypsilanti, Michigan.

As of February 2002, the Housing Authority operated four programs: (1) a Low-Income Housing
Program consisting of 198 units; (2) a Public Housing Drug Elimination Grant Program; (3)
Comprehensive Improvement Assistance Program; and (4) a Section 8 Housing Assistance
Program. The Low-Income Housing and Section 8 Housing Assistance Programs are designed to
provide housing to low and moderate-income individuals whose annual incomes does not exceed
80 percent of the median income for the surrounding community. HUD’s Drug Elimination Grant
Program provides grants to public housing authorities to reduce drug-related crime in and around
public housing sites. The Comprehensive Improvement Assistance Program funds capital
improvements and related management improvements in public housing developments to upgrade
living conditions, correct physical conditions, and achieve operating efficiency and economy.



                                    The audit objectives were to: (1) determine whether the
 Audit Objectives                   Housing Commission had sufficient controls for
                                    safeguarding cash and other monetary assets and inventory;
                                    and (2) review for waste, loss, and misuse of cash and other
                                    monetary assets and inventory.

                                    We conducted the audit at HUD’s Michigan State Office
 Audit Scope And                    and the Housing Commission’s office. We performed our
 Methodology                        on-site audit work between July 2000 and July 2001.

                                    To accomplish our audit objectives, we interviewed: HUD’s
                                    staff; the Housing Commission’s officials, staff, fee
                                    accountant, and independent public accountant; and one of
                                    the Commission’s tenants.

                                    We analyzed the following items: tenant files; cash
                                    disbursements and invoices; vendor files and contracts;
                                    vacancy reports; Public Housing Drug Elimination Program
                                    Grant vouchers; Board meeting minutes; payroll records and
                                    personnel files; equipment records; cash receipts and
                                    registers; general ledgers; tenant accounts receivable ledgers;
                                    audited financial statements; waiting list; rent rolls; and the
                                    Authority’s policies and procedures. We also reviewed:
                                    HUD’s files for the Commission; Sections 201, 309, 401,

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               and 407 of the Annual Contributions Contract between HUD
               and the Commission; Parts 24, 85, 901, and 990 of Title 24
               of the Code of Federal Regulations; HUD’s Public and
               Indian Housing Notice 96-35; Federal Register dated
               February 28, 1996, and HUD’s Accounting Guide 7510.1.

               The audit covered the period January 1, 2000 to December
               31, 2000. This period was adjusted as necessary. We
               conducted the audit in accordance with generally accepted
               government auditing standards.

               We provided a copy of this report to the Housing
               Commission's Executive Director and to the President of
               the Board.




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                                                                                      Finding 1


     The Commission’s Operating Subsidy Was
                    Inflated
The Ypsilanti Housing Commission improperly claimed an inflated operating subsidy. The
Commission did not adjust its subsidy claims for long-term vacant units and it inflated the
number of occupied units claimed. The Housing Commission’s Executive Director said she was
unaware of HUD’s requirements to reduce subsidy claims on long-term vacant units. She said
she also unaware that the Commission’s fee accountant inflated the number of occupied units.
Because the Commission improperly claimed an inflated operating subsidy, HUD paid $98,466
worth of excess operating subsidies to the Commission from July 1, 1996 to June 30, 2001.



                                   24 CFR Part 990.109 requires that if a Housing
 Federal Requirements              Commission has a vacancy rate greater than three percent,
                                   it must reduce the subsidy of units that have been vacant for
                                   more than 12 months to 20 percent of the allowable
                                   expense level.

                                   Section 309 of the Annual Contributions Contract, between
                                   HUD and the Ypsilanti Housing Commission, requires the
                                   Housing Commission to submit accurate and complete
                                   financial data to HUD.

                                   24 CFR Part 24 allows HUD to take administrative action
                                   against Housing Commission’s Executive Directors who
                                   violate HUD’s requirements. The administrative action
                                   includes debarment, suspension, and limited denial of
                                   participation.

                                   The Housing Commission did not adjust its operating
 Subsidy Not Adjusted For          subsidy to account for long-term vacancies from July 1,
 Long-Term Vacancies               1996 to June 30, 2000. The Housing Commission’s
                                   Executive Director said she became aware of the long-term
                                   vacancy rule when the Commission’s fee accountant
                                   reported the long-term vacancy adjustment for Fiscal Year
                                   2001. However, the Commission’s Executive Director
                                   contradicted herself in a subsequent interview when she
                                   said she was unaware of the requirement. Regardless, the
                                   Commission’s Executive Director discussed the Fiscal Year
                                   2001 long-term vacancy adjustment with a HUD official.
                                   The Housing Commission also had knowledge of the rule
                                   when HUD distributed Public and Indian Housing Notice

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                                           96-35 to all public housing agencies on June 4, 1996. The
                                           Notice explained the long-term vacancy adjustment
                                           requirement. HUD also published a Final Rule in the
                                           Federal Register on February 28, 1996 that included the
                                           need for housing agencies to reduce their subsidy request
                                           for long-term vacant units. As a result, the Commission
                                           received $98,466 worth of excess subsidies between Fiscal
                                           Year 1997 and Fiscal Year 2001.

                                           The Housing Commission did not adjust subsidy claims to
                                           account for long-term vacancies once the Commission’s
                                           Executive Director had knowledge of the rule.

                                           The Housing Commission reported 26 long-term vacant
                                           units from July 1, 2000 to June 30, 2001. However, HUD
                                           adjusted the number of long-term vacant units to zero
                                           because the Commission’s Executive Director told officials
                                           that the same unit did not remain vacant over the 12-month
                                           period. This made the 26 units eligible for the full subsidy
                                           payment. The actual number of long-term vacant units was
                                           four.     Because the Commission’s Director provided
                                           misleading information, HUD paid an additional $5,313
                                           worth of subsidies for Fiscal Year 2001.

                                           The table below illustrates the excess subsidy paid due to
                                           the omission of long-term vacant units from July 1, 1996 to
                                           June 30, 2001. Each Fiscal Year represents an annual
                                           operating subsidy claim. The vacancy rate for Fiscal Year
                                           2001 represents July 1, 2000 to December 31, 2000.

                                 Audited
                                  Long-      Claimed                     Operating                    Excess
                                  Term         Unit      Audited Unit   Subsidy Paid    Audited       Subsidy
  Fiscal       Vacancy           Vacant       Months       Months           And        Operating     Paid And
  Year          Rate     Units    Units      Available    Available      Obligated      Subsidy      Obligated
   1997         18%      218       18         2,616         2,400         $359,066       $334,882    $24,184
   1998         18%      218       10         2,616         2,496          442,607        428,303     14,304
   1999         19%      215       23         2,580         2,304          429,527        398,347     31,180
   2000         18%      198       4          2,376         2,328          353,665        348,339      5,326
   2001         17%      198        4         2,376         2,328          431,756        426,443      5,313
                                                                        $2,016,621     $1,936,314    $80,307

                                           The Housing Commission inflated the number of occupied
 Occupancy Level Inflated                  units it claimed for operating subsidy from July 1, 2000 to
                                           June 30, 2001. The Commission claimed 172 occupied
                                           units when it had 159 occupied units. The Housing
                                           Commission’s Executive Director said the Commission’s

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                                                                                        Finding 1


                                  fee accountant prepared the claim. The fee accountant said
                                  the Commission provided the number of occupied units.
                                  The Commission’s Tenant Accounts Receivable Report and
                                  the Vacancy Report both identified 159 occupied units.
                                  Because the Commission inflated the number of occupied
                                  units, HUD paid $18,159 in excess operating subsidy for
                                  Fiscal Year 2001.

                                  The table below illustrates the excess subsidy paid due to
                                  an inflated occupancy level.

                    Fiscal Year   Occupied    Operating       Adjustment For      Excess Operating
                       2001        Units     Subsidy Paid   Long-Term Vacancies       Subsidy
                     Claimed        172       $431,756
                     Audited        159        408,284
                    Difference       13        $23,472           ($5,313)              $18,159

                                  The Housing Commission did not develop procedures and
Management Controls               controls to provide reasonable assurance that operating
Over Operating Subsidy            subsidy claims were accurate. The Housing Commission’s
Claims Were Weak                  Executive Director said she relied on the Commission’s fee
                                  accountant to accurately prepare the claim. The fee
                                  accountant said the Commission provided him inaccurate
                                  information. Procedures should identify what information
                                  should be provided to the fee accountant or used in
                                  preparing the claim, whom will review the claim for
                                  accuracy, and how the Commission will ensure the use of
                                  updated rules and regulations.




Auditee Comments                  [Excerpts paraphrased from the Ypsilanti Housing
                                  Commission’s comments our draft finding follow.
                                  Appendix B, pages 35 to 38, contains the complete text of
                                  the comments for this finding.]

                                  The recalculation of the long-term vacancies by the OIG
                                  appears to be correct; however, the explanation of the
                                  Executive Director’s knowledge is incorrect. The Housing
                                  Commission’s Executive Director was absolutely unaware of
                                  the required adjustment until HUD questioned it as a result
                                  of the 2001 budget submission. The correction has not been
                                  taken because the Commission’s Executive Director was
                                  awaiting the results of the OIG audit.


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                     The Housing Commission would agree to repay the $98,466
                     by either de-obligating the funds from the Commission’s
                     2002 budget, or repayment directly to HUD.            The
                     Commission’s Executive Director does not believe referrals
                     or administrative actions are necessary under the
                     circumstances. The cost for both the Federal government
                     and the Commission would be unwarranted and counter
                     productive.

                     The Commission would agree to hire a finance manager to
                     assist in form preparation, grant writing, and strengthening of
                     internal controls.



 OIG Evaluation Of   We disagree that the Housing Commission’s Executive
 Auditee Comments    Director was unaware of the required long-term vacancy
                     adjustment until the 2001 budget submission.          HUD
                     distributed Public and Indian Housing Notice 96-35 to all
                     public housing agencies on June 4, 1996. The Notice
                     explained the long-term vacancy adjustment requirement.
                     Additionally, HUD has continually issued notices since 1996
                     that related to operating subsidy calculations.

                     HUD should take the appropriate administrative action
                     against the Housing Commission’s Executive Director
                     because of her failure to administer the Commission
                     according to HUD’s requirements.



 Recommendations     We recommend that the Michigan State Office Director of
                     Public Housing Hub assure that the Ypsilanti Housing
                     Commission:

                     1A.      Reimburses HUD $98,466 ($80,307 plus $18,159)
                              from non-Federal funds for the excess subsidy
                              payments received for the long-term vacancies and
                              the inaccurate occupied units reported.

                     1B.      Implements procedures and controls to follow HUD’s
                              regulation and the Annual Contributions Contract
                              regarding claims for operating subsidies.




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       We also recommend that the Michigan State Office Director
       of Public Housing Hub:

       1C.    Pursues administrative action against the Housing
              Commission’s Executive Director based upon the
              information cited in this report as permitted by 24
              CFR Part 24.




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                                                                                    Finding 2


       The Commission Needs To Reduce High
                 Vacancy Rates
The Ypsilanti Housing Commission did not maintain an acceptable level of occupancy. Despite
a waiting list of 131 applicants, the Commission’s vacancy rate at December 31, 2000 was 17.5
percent. The Commission considers the vacancy rate to be acceptable. The Commission’s
continued failure to reduce vacancies identified in prior OIG audits has resulted in lost
opportunity for low-income families to obtain affordable housing. The Commission lost an
estimated $157,286 worth of rental income from January 1, 1997 to December 31, 2000 because
of its high vacancy rates.



                                   Section 201 of the Annual Contributions Contract, between
 Federal Requirements              HUD and the Ypsilanti Housing Commission, requires the
                                   Commission to provide public housing in an efficient,
                                   economic, and stable manner to low-income eligible
                                   tenants.

                                   24 CFR Part 901.10 provides indications on how well a
                                   Housing Commission is performing. Part 901.10 states an
                                   actual vacancy rate greater than ten percent is the lowest
                                   score a Commission can receive. The Part also provides
                                   that an average turnaround greater than 50 days is the
                                   lowest score a Commission can receive.

                                   The Housing Commission’s Maintenance Policy requires
 Commission’s Policy               that vacant units be prepared for occupancy within an
                                   average of seven calendar days from the date vacated.

                                   As of December 31, 2000, the Housing Commission had a
 High Vacancy Rate                 vacancy rate of 17.5 percent when 34 of 194 units were
                                   vacant. The Commission’s Executive Director said the
                                   fundamental problem was due to a shortage of maintenance
                                   employees. The Director also said units remained vacant
                                   because: units were set aside for an activity center; and
                                   applicants did not want to live in the less desirable
                                   Parkridge Homes project. The Housing Commission could
                                   not provide any records to support that the units were
                                   inhabitable. Further, our inspection of five vacant units
                                   disclosed that the amount of work necessary to prepare the
                                   units for occupancy was minimal to moderate. We were
                                   unable to determine if crime rates contributed to the high

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                                  vacancy rate at Parkridge Homes. HUD did not approve
                                  any units to be set aside for an activity center. The
                                  Commission’s Executive Director said she believed the
                                  vacancy rate was acceptable. The following pie chart
                                  illustrates the number of vacant days for the 34 vacant
                                  units. The number next to each segment within the chart
                                  represents the number of vacant units. For example, four
                                  units were vacant for over four years and eight units were
                                  vacant for over one year.


                                  Thirty-Four Vacant Units
                                    Number of Vacant Days



            0 to 30 days                        4                3
                                                                     1
        31 to 60 days                                                     4
        61 to 90 days         8
        91 to 180 days
       181 to 365 days
                                                                               2
       over 1 year
       over 4 years
                                                            12




                                  Because the Housing Commission failed to reduce its
 Lost Rental Income               vacancy rate, the Commission lost an estimated $157,286
                                  ($38,606 plus $38,797 plus $42,923 plus $36,960) worth of
                                  rental income from January 1, 1997 to December 31, 2000.
                                  The following table shows our computation of the lost
                                  rental income. The annual unit months were adjusted to
                                  allow for a three percent vacancy rate.

                                              1997        1997         1999          2000
 Adjusted Annual Unit Months Available        2,490       2,490        2,335         2,258
 Less: Annual Occupied Unit Months            2,069       2,092        1,934         1,883
 Equals Lost Unit Months                        421         398          401           375
 Multiplied by Rent Per Unit Month           $91.70      $97.48      $107.04        $98.56
 Lost Annual Rental Income                  $38,606     $38,797      $42,923       $36,960

                                  Low occupancy levels have been a continuous problem at
 The Commission Did Not           the Housing Commission. In May 1982, an OIG audit
 Correct Its Vacancy              disclosed the Commission’s vacancy rate was 19 percent.
 Problem                          The Commission cited a lack of funds to rehabilitate the
                                  vacant units as the primary reason for the excessive
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                         vacancies. In November 1992, another OIG audit revealed
                         a vacancy rate of 13 percent. The Commission reported
                         that the high vacancy rate was due to insufficient
                         maintenance staffing levels. The annual average vacancy
                         rates for 1998 and 1999 were 18 and 19 percents,
                         respectively.

                         As a result of the 1992 OIG audit, the Housing Commission
                         agreed to assign one maintenance employee to work on
                         vacant units full time or hire an outside work crew for the
                         vacant unit preparation. The Commission did not adhere to
                         the agreement. The Housing Commission’s Executive
                         Director said it was difficult assigning one worker to
                         prepare vacant units with only two maintenance employees.
                         If one maintenance employee was absent or assigned to
                         other tasks, the second employee was needed to service
                         work orders. The Executive Director said the Commission
                         did not have the money to hire an outside crew.

                         The Housing Commission’s maintenance staff level was
                         low compared to similar commissions. Three comparable
                         public housing commissions reported employing a full-time
                         maintenance supervisor and between two and four
                         maintenance staff. This is compared to the Housing
                         Commission’s part-time maintenance supervisor and two
                         maintenance staff.

                         The Housing Commission’s Board of Commissioners did
Controls Over            not properly monitor the vacancy level. The November
Maintenance Operations   1992 OIG audit resolution required the Commission’s
Were Weak                senior management and Board of Commissioners to review
                         monthly maintenance reports on the status of each unit.
                         Board meeting minutes revealed that the Commission did
                         not review the monthly status of each unit. The Housing
                         Commission’s Executive Director said the Board was not
                         interested in the details of individual vacant units.

                         The Housing Commission did not properly supervise its
                         maintenance activities. The Commission dismissed its full-
                         time maintenance supervisor in August 1998 for
                         unacceptable conduct toward tenants. From August 1998
                         to March 1999, the Commission operated without a
                         maintenance supervisor. In March 1999, the Commission
                         contracted with a construction company to provide part-
                         time maintenance supervision three days a week. The

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                       Commission’s Executive Director said an employment
                       vacancy for a maintenance supervisor was advertised, but
                       no one qualified applied. As an alternative solution, the
                       Commission employs two full time maintenance staff and
                       contracts for part-time supervision.

                       As of December 31, 2000, the Housing Commission’s
  Waiting List Was     waiting list consisted of 131 applicants. The list was
  Sufficient To Fill   sufficient to fill 29 of the 34 vacant units. The remaining
  Vacancies            applicants could have been placed into larger units in
                       accordance with the Commission’s Admissions and
                       Occupancy Plan.



 Auditee Comments      [Excerpts paraphrased from the Housing Commission’s
                       comments on our draft finding follow. Appendix B, pages
                       38 and 39, contains the complete text of the comments for
                       this finding.]

                       The OIG documented that the Housing Commission has
                       had a high vacancy rate for several years. This fact is not
                       being disputed. However, the Commission’s Executive
                       Director does not agree with the statement that she found
                       the vacancy rate to be acceptable.

                       Several obstacles contributed to the Housing Commission’s
                       inability to correct the vacancy problem. They include: (1)
                       applicants refusing units due to criminal activity, age of
                       units, and lack of space; (2) the One Strike Policy resulted
                       in a large number of evictions; (3) several public housing
                       residents moved because they received Section 8 assistance;
                       and (4) a lack of maintenance staff.

                       The Housing Commission agrees that the controls over the
                       maintenance operations are weak. This problem is due in
                       part that the Commission has not had a full time
                       maintenance supervisor.

                       The OIG states that the waiting list was sufficient to fill 29
                       of the 34 vacancies. The Housing Commission’s Executive
                       Director does not necessarily agree with this statement.
                       There is no guarantee that every applicant would have been
                       willing to accept a unit that may have been available at
                       Parkridge Homes.

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                    The Housing Commission would agree to hire a full time
                    maintenance supervisor and sufficient staff to reduce the
                    high vacancy rate.



OIG Evaluation Of   The Housing Commission stated that its Executive Director
Auditee Comments    does not agree that she found the vacancy rate to be
                    acceptable. We disagree. The Commission’s management
                    controls did not include monitoring, controlling, or
                    preventing excessive vacancies since first reported by OIG in
                    May 1982. The reason for the Commission’s high vacancy
                    rate has remained the same for almost 20 years.

                    We disagree that the Housing Commission’s waiting list was
                    insufficient to fill 29 of the 34 vacancies. The waiting list
                    consisted of 131 applicants at the time of our audit. If an
                    applicant refuses a unit, then that applicant would be place at
                    the bottom of the Commission’s waiting list allowing other
                    applicants to occupy the unit. In addition, the Commission’s
                    Admissions Policy allows families to be housed in larger size
                    units provided the applicant agrees to move to the proper size
                    unit when units become available.



 Recommendations    We recommend that the Michigan State Office Director of
                    Public Housing Hub assure the Ypsilanti Housing
                    Commission:

                    2A.    Hires sufficient maintenance staff to reduce the high
                           vacancy rate.

                    2B.    Implements a plan to reduce vacancies that includes
                           filling vacancies from the Commission’s waiting list.

                    2C     Prepares vacant units for occupancy within an
                           average of seven calendar days from the date vacated
                           as required by its Maintenance Policy.

                    2D.    Implements procedures and controls to ensure that its
                           Executive Director and Board of Commissioners
                           monitors the status of vacant units as necessary to
                           assure that the Commission finally reduces its
                           vacancy rate.

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                                                                                         Finding 3


        Controls For Safeguarding Assets Need
                    Strengthening
The Ypsilanti Housing Commission did not safeguard its cash and other monetary assets against
possible waste, loss, and misuse. Management controls over cash receipts, deposits,
disbursements, equipment, procurement, and financial and administrative processes were weak.
The weaknesses can be attributed to the Commission’s lack of knowledge or expertise of HUD’s
requirements, lack of procedures and controls, and errors. As a result, HUD lacks assurance that
the Commission’s cash and other monetary assets were safeguarded against waste, loss, and
misuse.



                                    24 CFR Part 85.20 requires Housing Commissions to
 Federal Requirements               establish good cash management procedures. Part 85.20
                                    also requires that effective controls and accountability be
                                    maintained for all assets and the assets be safeguarded. The
                                    Commission’s accounting records are to be supported by
                                    source documents and its financial management system is
                                    to be accurate, current, and complete. Part 85.20 states that
                                    records must identify the source and application of funds
                                    provided for financially assisted activities.

                                    24 CFR Part 85.32 requires Housing Commissions to
                                    maintain detailed property records, take a physical
                                    inventory every two years, and reconcile the inventory with
                                    property records. The Commission’s records must show
                                    the property description, source, title, cost, acquisition date,
                                    location, use, and condition.

                                    24 CFR Part 85.36(c) requires Housing Commissions to
                                    conduct all procurement transactions in a manner to
                                    provide full and open competition. Part 85.36(b) requires
                                    Commissions to maintain sufficient records to show the
                                    procurement history.

                                    Section 309 of the Annual Contributions Contract, between
                                    HUD and the Ypsilanti Housing Commission, requires the
                                    Housing Commission to maintain current, complete, and
                                    accurate books of accounts. Section 401 of the Contract
                                    requires the Commission to secure all deposits in excess of
                                    the $100,000 insured amount and execute a Depository
                                    agreement with its bank to give HUD authority over the

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                     Commission’s accounts. Section 401 also requires the
                     Commission to invest General Fund monies not needed for
                     the next 90 days into HUD-approved investment securities
                     and that all funds received are deposited promptly.

                     Section 407 of the Annual Contributions Contract prohibits
                     the Housing Commission from incurring expenditures in
                     excess of amounts in approved Operating Budgets for
                     controlled accounts, except for emergencies involving an
                     immediate serious hazard to life, health, or safety of the
                     residents.

                     HUD’s Accounting Guide 7510.1, Section II, states that
                     procedures over cash should include a segregation of
                     duties.

                     Management controls over cash receipts and deposits were
 Cash Receipts And   weak.
 Deposits Were Not
 Safeguarded         ·   The Housing Commission did not collateralize bank
                         balances that exceeded the $100,000 Federal Deposit
                         Insurance Corporation coverage per the Commission’s
                         financial institution. The Commission’s Executive
                         Director said she was unaware of the requirement.
                         However, the Commission’s independent auditor
                         reported the same condition in the 1999 financial
                         statements audit report. The Commission’s Executive
                         Director said she did not read the entire report. As of
                         December 29, 2000, the Commission had $575,568
                         worth of uninsured funds on deposit at one financial
                         institution.

                     ·   The Housing Commission did not execute a Depository
                         Agreement to give HUD the authority to exercise
                         control over the Commission’s bank accounts. The
                         Commission’s Executive Director said a General
                         Depository Agreement existed, but it could not be
                         located. However, bank officials could not provide us
                         with a copy of the Agreement either. Without the
                         authority, HUD could not exercise control over the
                         Housing Commission’s bank accounts in the event
                         HUD declares a breach of the Annual Contributions
                         Contract with the Commission.



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                         ·    The Housing Commission did not invest excess funds
                              into HUD-approved investment securities.            The
                              Housing Commission’s Executive Director said the
                              Commission did not have the time or expertise to invest
                              excess funds and considered its interest-bearing bank
                              accounts to be sufficient. However, since HUD
                              provides sufficient investment guidance, the
                              Commission would not need to spend an excessive
                              amount of time or require expertise. Additionally, the
                              Annual    Contributions     Contract     requires    the
                              Commission to invest its excess funds into approved
                              investment securities. As a result, we estimate that the
                              Commission lost the opportunity to earn $6,161 worth
                              of investment interest between January 1, 2000 and
                              December 31, 2000.

                         ·    The Housing Commission did not deposit rents and other
                              receipts in a timely manner. The Annual Contributions
                              Contract requires that all funds received be deposited
                              promptly.      The Commission’s Executive Director
                              believed promptly meant one to three days. We reviewed
                              260 deposits for the period July 1, 1999 to December 31,
                              2000. A total of 94 deposits (36 percent) were not made
                              within five days after the funds were collected. For
                              example, the Commission collected $10,055 between
                              June 2, 2000 and June 6, 2000 but did not deposit the
                              funds until June 12, 2000, a delay of six to ten days. The
                              Commission’s current Accounting Assistant said she
                              followed the practice of the prior Accounting Assistant
                              by making weekly bank deposits. If the Housing
                              Commission had a written collection policy in place, the
                              Commission’s Accounting Assistant would have known
                              to make timely deposits. As a result, the Commission
                              took increased risks by keeping the receipts on its
                              premises for an excessive period of time.

                         Management controls over cash disbursements were weak.
Disbursements Were Not
Safeguarded              The Housing Commission did not segregate duties over its
                         petty cash fund and check disbursements.              The
                         Commission’s Accounting Assistant had custody of the
                         petty cash fund, blank checks, signature plates, and bank
                         deposits. The Assistant also maintained custody of the
                         Commission’s accounting records. In effect, the Housing
                         Commission’s Accounting Assistant had complete control

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               over the Commission’s accounting system, which could
               lead to misuse.

               In part, the Housing Commission’s petty cash
               disbursements were not segregated due to the Executive
               Director’s medical leave of absence in February 2001.
               Additionally, the Housing Commission’s Executive
               Director said the Commission’s small staff size did not
               allow for a complete segregation of duties. We determined
               that even though the Housing Commission had a small staff
               of five, duties could have been segregated to ensure no one
               person had complete control over the Commission’s
               transactions.

               The Housing Commission could not support that all
               disbursements were made for reasonable operating
               expenses or necessary repairs.

               ·   We reviewed 50 out of 3,167 General Fund invoices for
                   the period October 1, 1998 to September 30, 2000 to
                   determine whether the Housing Commission had
                   supporting documentation.     Four invoices lacked
                   supporting documentation.

               ·   HUD’s Michigan State Office of Public Housing Hub
                   cited the Housing Commission in its November 29, 2000
                   monitoring report for unsupported Drug Elimination
                   Grant expenditures. HUD’s review was conducted on
                   June 19, 2000 and June 20, 2000. As a follow-up, we
                   reviewed three subsequent Drug Elimination Grant
                   vouchers for supporting documentation. Eleven invoices
                   lacked supporting documentation.

               The Housing Commission’s Executive Director said she
               believed that the expenditures were supported by source
               documentation.     However, the Commission lacked
               procedures and controls to ensure expenditures were
               supported by source documentation. As a result, the
               Commission lacked assurance that $11,850 worth of
               General Fund disbursements and $5,431 worth of Drug
               Elimination Grant disbursements was used for their
               intended purpose. The table on page 20 of this report
               shows the unsupported expenditures.



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       The Housing Commission was reimbursed for duplicate and
       ineligible Drug Elimination Grant expenditures.

       ·    Wages for three of the Commission’s employees and the
            purchase of signs were double billed. The excess
            reimbursement to the Commission totaled $2,827.

       ·    An expenditure of $500 for a parking lot expense was not
            eligible for reimbursement, but was paid by the
            Commission.

       The Housing Commission’s Executive Director said she
       believed that the above expenditures were allowable and
       supported by source documentation.           However, the
       Commission’s Director was unaware of the duplicate
       reimbursements. HUD previously notified the Commission
       that the parking lot expenditure was not allowable. We
       determined that the Commission lacked procedures and
       controls over expenditures. As a result, the Commission
       lacked assurance that $3,327 ($2,827 plus $500) worth of
       Drug Elimination Grant disbursements was used for their
       intended purpose. The table on page 20 of this report
       shows the duplicate and ineligible expenditures.




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                                                                                                Audited
  Date      Number       Amount               Payee             Payment Explanation             Results
Unsupported General Fund Expenses
 9/16/99      11584         $2,925     Motor City Asphalt      Repair turnaround at Paradise   No support
                                                               Manor.
  9/16/99      11585           2,925   Motor City Asphalt      Repair turnaround at Paradise   No support
                                                               Manor.
  9/30/99       11653          2,000   H.A. Hasan, PhD         EMU/Vista Program               No support
                                                               Collaboration.
   3/9/00       12368          4,000   H.A. Hasan, PhD         Hope VI/Vista Program           No support
                                                               Supervisor.
        Total               $11,850
Unsupported Public Housing Drug Elimination Grant Program Expenses
 9/28/00      110944         $ 515 Diamond Computers      Computer supplies                    No support
              110944            200 Advanced Blind        Blinds for Learning Center           No support
              110944             90 A. Williamson         Posters for Learning Center          No support
              110944            146 Wal-Mart              Unknown.                             No invoice
              110944            903 Wal-Mart              Unknown.                             No invoice
              110944            348 Wal-Mart              Unknown.                             No invoice
              110944            400 Sam’s Club            New software, videos, etc.           No support
              110944            200 Play-It-Again Sports  Sports equipment for Hollow          No support
                                                          Creek Center
              110944          2,500 Jordan Tae Kwon Do Karate classes & equipment –            No support
                                                          30 youth
11/30/00      114227             80 A. Williamson         Supplies                             No support
              114227             49 Mattel Interactive    Software replacement                 No support
        Total                $5,431
Public Housing Drug Elimination Grant Program Duplicate Claim Costs
 7/21/99      088469          $2,292 FastSigns             Estimate Number 5074 for            Duplicate
                                                            various signs and wooden           Claim
                                                            posts.
11/30/00      114227             177 A. Jones (employee)    Replacement check for wages        Duplicate
                                                                                               Claim
 11/30/00      114227           204    R. Frasier (employee)   Replacement check for wages     Duplicate
                                                                                               Claim
 11/30/00      114227           154    C. Ervin (employee)     Replacement check for wages     Duplicate
                                                                                               Claim
        Total                 $2,827
Public Housing Drug Elimination Grant Program Ineligible Costs
 9/28/00      110944            $500 Bateson Farms & Co. Parking lot paving expense.           Ineligible
        Total                   $500


                                       Controls over check disbursements were weak. The
                                       Housing Commission’s check register did not reconcile with
                                       source documents. For example, manual check numbers
                                       13110 through 13112 did not include the check amount in
                                       the Commission’s register. The Commission’s Executive
                                       Director said she could not explain why the errors occurred.
                                       We believe the lack of procedures and controls by the

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                          Commission to ensure that the check register reconciled with
                          source documents caused the errors to go undetected. As a
                          result, the Commission could issue checks in excess of funds
                          on hand.

                          The Housing Commission’s management controls over
Equipment Was Not         equipment accountability were weak for equipment
Safeguarded               purchased with Federal funds. The Commission failed to
                          perform physical inventory reconciliations, itemize donated
                          equipment, and maintain detailed property records. For
                          example, one invoice identified the purchase of six
                          computers on October 29, 1998 for $6,870. The computer
                          equipment was not recorded in the Commission’s property
                          ledger. The Housing Commission’s Executive Director
                          said she was not fully aware of Federal requirements for
                          safeguarding equipment. However, HUD’s requirements
                          identified specific record keeping guidance. As a result, the
                          Commission cannot provide assurance that all equipment
                          was accounted for and used for its intended purpose.

                          The Housing Commission did not always conduct
Procurement Controls      procurements in a manner to provide full and open
Were Weak                 competition. For example, the Commission did not
                          advertise or solicit price quotes for legal services. The
                          Commission has had legal services provided by the same
                          law firm since 1992 without advertising or soliciting
                          competitive price quotes. The Commission paid $16,667
                          for legal services between January 1, 2000 and December
                          31, 2000. The Commission’s Executive Director said the
                          Commission had not always advertised for procurements.
                          She also said the Commission had been very satisfied with
                          the services. Regardless, the Housing Commission’s
                          procurement policy required the Commission to advertise
                          or mail out invitations to bid on contracts in excess of
                          $5,000. As a result, HUD lacks assurance that the lowest
                          price was obtained for the Commission’s procurement
                          transactions, and that there was full and open competition.

                          The Housing Commission’s budgetary controls were weak.
Financial And             The Commission did not control cost overruns and failed to
Administrative Controls   obtain HUD’s approval for the overruns.               The
Were Weak                 Commission’s Fiscal Year 2000 financial statements
                          showed budget overruns totaling $241,423 in
                          administration, utilities, ordinary maintenance, employee
                          benefit contributions, and insurance. The Commission’s

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                             Executive Director said she could not explain the cost
                             overruns, but believed high unit repair costs contributed to
                             the overruns. However, we determined the Commission’s
                             lack of controls contributed to the budget overruns.
                             Because of the lack of controls, the Commission did not
                             know when it reached its budget authority. Accurate
                             budgeting is important to ensure the efficient and effective
                             use of funds.

                             The Housing Commission’s weak management controls over
 Controls For Safeguarding   petty cash, unsupported disbursements, equipment
 Assets Have Been A          accountability, and procurement practices have been a
 Continuous Problem          continuous problem.

                             In May 1982, an OIG audit revealed that the Commission
                             had not established effective controls over investments, cash
                             receipts, cash disbursements, equipment records, and
                             procurement. In November 1992, another OIG audit
                             revealed the Commission continued to experience similar
                             deficiencies. For example, the Commission failed to
                             establish effective management controls for safeguarding
                             cash receipts, cash disbursements, procurement, petty cash,
                             property, and equipment.

                             In an effort to resolve the previous OIG audits, the Housing
                             Commission agreed to improve its management controls.
                             The Housing Commission’s Executive Director said the
                             Commission had not complied with the agreement. Because
                             the Housing Commission failed to implement the necessary
                             controls, HUD lacks assurances that the Commission’s cash
                             and other monetary assets were safeguarded against waste,
                             loss, and misuse.



   Auditee Comments          [Excerpts paraphrased from the Housing Commission’s
                             comments on our draft finding follow. Appendix B, pages
                             40 to 45, contains the complete text of the comments for
                             this finding.]

                             The Housing Commission disagrees that it did not safeguard
                             cash and other assets against possible waste, loss, and
                             misuse. The Commission does have safeguards in place to
                             protect its cash and other assts from waste, loss, or misuse.
                             Missing cash or assets were not reported and there are no

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       material weaknesses. The Housing Commission agrees that
       due to several circumstances, some of the controls were less
       than adequate.

       OIG suggests that the disbursements were not safeguarded
       and that management controls were weak. However, OIG
       offers very little to support its statements. The Housing
       Commission asserts that disbursements were safeguarded
       and management controls were adequate.

       OIG’s draft finding states that equipment was not
       safeguarded and computers purchased with grant money
       were not used for their intended purpose. However, the draft
       finding offers no support or basis for the comment. The
       Commission’s position is that all equipment is safeguarded
       and the computers are being used for their intended purpose.

       The draft finding states that procurements were not always
       conducted in a manner to provide for full and open
       competition. The example used in the finding is for legal
       services. The finding states that in calendar year 2000 the
       Commission paid $16,667 for legal services and its in
       excess of the $5,000 threshold for getting competitive bids.
       The Commission believes that its procurement policy was
       and is being followed. The amount of money that will be
       paid for legal services during any given year is not known
       or stated in the contract; therefore, the Commission was not
       in excess of the $5,000 limit when it contracted for the
       legal services.

       The Housing Commission’s new Finance Director is
       responsible for reviewing and improving the Commission’s
       budgeting and tracking process. The Commission is using
       new software and spreadsheets for this process. When the
       Housing Commission purchases a new accounting package
       and it is installed, there will be new management reports
       that will provide the Commission better and timelier
       reporting. One such report will show budget-to-actual
       comparisons for current months and the year-to-date
       expenditures. Included in the new software is a purchase
       order system that will improve the Commission’s internal
       controls and approval process. Any potential cost overruns
       will be detected well in advance and year-end budget
       revisions will be made, if necessary.


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                       OIG makes reference to past audit findings and that the
                       Commission’s cash and assets were not safeguarded. The
                       draft finding states this is a continuous problem that the
                       Commission has not fixed. The Commission believes that
                       its cash and assets were safeguarded, and this is not a
                       continuous problem. Again, there were no findings of loss,
                       waste, or misuse.



   OIG Evaluation Of   We disagree that the Housing Commission has safeguards in
   Auditee Comments    place to protect its cash and other monetary assets from
                       waste, loss, or misuse. In fact, the Commission’s weak
                       management controls have existed for almost 20 years. In
                       May 1982, an OIG audit disclosed that the Commission had
                       not established effective controls over investments, cash
                       receipts, cash disbursements, equipment records, and
                       procurement. In our November 1992 audit, OIG reported
                       that the Commission continued to experience similar
                       deficiencies.

                       We disagree that disbursements were safeguarded and
                       management controls were adequate. We consider the
                       Housing Commission’s lack of segregation of duties over
                       petty cash and check disbursements, and the Commission’s
                       inability to reconcile its check register with source
                       documents to be a weak management control. The lack of a
                       system of records to ensure supporting documents were
                       maintained for disbursements to be a weak management
                       control. Furthermore, the Housing Commission’s failure to
                       implement procedures and controls to ensure reimbursements
                       are not claimed twice, and the payment of ineligible and
                       unsupported expenses to support the Commission’s weak
                       controls.

                       The Housing Commission’s hiring of a new Finance Director
                       and the purchase of new computer software should improve
                       its management controls, if effectively implemented.



   Recommendations     We recommend that the Michigan State Office Director of
                       Public Housing Hub assure the Ypsilanti Housing
                       Commission:


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       3A.   Implements procedures and controls to safeguard
             cash receipts, deposits, disbursements, equipment,
             procurement, and financial and administrative
             processes against waste, loss, and misuse. The
             procedures at a minimum should include:

             ·    Investing excess General Fund money into
                  HUD-approved investment securities;

             ·    Depositing cash receipts in a timely manner;

             ·    Segregating petty cash and disbursement duties
                  so no one person has complete control over the
                  petty cash fund, blank checks, signature plates,
                  bank deposits, and the preparation of accounting
                  records;

             ·    Supporting all purchases with source documents
                  to ensure disbursements were used for their
                  intended purpose;

             ·    Reconciling all checks and the check register
                  with source documents;

             ·    Maintaining a detailed property ledger and take
                  a bi-annual physical inventory to account for all
                  of the Commission’s property;

             ·    Conducting procurement transactions in a
                  manner to provide full and open competition,
                  and maintain records to support the rational and
                  justification of the procurement process;

             ·    Establishing a system of records to separate
                  accounting activities for the Commission’s
                  activities/programs;

             ·    Ensuring accounting and financial records are
                  current, complete, and accurate; and

             ·    Preventing expenditures in excess of approved
                  budget amounts for controlled accounts.




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               3B.      Provides training to its staff in procedures and
                        controls necessary to safeguard cash and other
                        monetary assets against waste, loss, and misuse.

               3C.      Executes a collateralization agreement for its bank
                        accounts that exceed the $100,000 Federal Deposit
                        Insurance Corporation coverage.

               3D.      Executes a Depository Agreement with its financial
                        institution to give HUD authority over all accounts.

               3E.      Provides documentation to support the $17,281
                        ($11,850 plus $5,431) worth of unsupported
                        disbursements cited in this finding. If the Housing
                        Commission        cannot     provide      supporting
                        documentation, the Commission should reimburse
                        its appropriate program(s) from non-Federal funds
                        for the applicable amount.

               3F.      Reimburses HUD $3,327 ($2,827 plus $500) from
                        non-Federal funds for the duplicate and ineligible
                        costs cited in this finding.




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Management Controls
In planning and performing our audit, we considered the management controls of the Ypsilanti
Housing Commission 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 controls were
 Relevant Management                  relevant to our audit objectives:
 Controls

                                      ·   Program Operations - Policies and procedures that
                                          management has implemented to reasonably ensure that a
                                          program meets its objectives.


                                      ·   Validity and Reliability of Data - Policies and procedures
                                          that management has implemented to reasonably ensure
                                          that valid and reliable data are obtained, maintained, and
                                          fairly disclosed in reports.


                                      ·   Compliance with Laws and Regulations - Policies and
                                          procedures that management has implemented to
                                          reasonably ensure that resource use is consistent with
                                          laws and regulations.


                                      ·   Safeguarding Resources - Policies and procedures that
                                          management has implemented to reasonably ensure that
                                          resources are safeguarded against waste, loss, and
                                          misuse.

                                      We assessed all of the relevant controls 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 items are
 Significant Weaknesses               significant weaknesses:

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                      ·   Program Operations

                      The Housing Commission was not operated according to
                      program requirements. Specifically, the Commission:
                      improperly claimed $98,466 of inflated operating subsidy
                      since it did not adjust its subsidy claim for long-term vacant
                      units and it inflated the number of occupied units; did not
                      maintain an acceptable level of occupancy; failed to
                      collateralize bank balances that exceeded the $100,000
                      Federal Deposit Insurance Corporation coverage; did not
                      execute a Depository Agreement to give HUD the authority
                      to exercise control over its bank accounts; failed to invest
                      excess funds into HUD-approved investment securities; did
                      not deposit rents and other receipts in a timely manner;
                      failed to segregate duties over its petty cash and check
                      disbursements; could not support $11,850 of Low-Rent
                      Housing Program disbursements and $5,431 in Public
                      Housing Drug Elimination Program disbursements;
                      improperly spent $3,327 of Drug Elimination Program
                      funds for duplicate and ineligible costs; did not safeguard
                      equipment; failed to always conduct procurements in a
                      manner to provide full and open competition; and did not
                      control cost overruns and obtain HUD’s approval on the
                      overruns (see Findings 1, 2, and 3).

                      ·   Validity and Reliability of Data

                      The Housing Commission: provided misleading
                      information to HUD regarding the number of long-term
                      vacant units; inflated the number of occupied units it
                      claimed for operating subsidy from July 1, 2000 to June 30,
                      2001; and did not record computer equipment in its
                      property ledger (see Findings 1 and 3).

                      ·   Compliance with Laws and Regulations

                      The Housing Commission did not follow HUD’s
                      regulations regarding operating subsidy requests and
                      safeguarding of assets (see Findings 1 and 3).

                      ·   Safeguarding Resources

                      The Housing Commission: improperly claimed $98,466 in
                      excess operating subsidy; lacked documentation to support
                      $11,850 of Low-Rent Housing disbursements and $5,431 in

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       Public Housing Drug Elimination Program disbursements;
       and inappropriately used $3,327 of Drug Elimination
       Program funds to pay for duplicate and ineligible costs (see
       Findings 1 and 3).




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Follow Up On Prior Audits
HUD’s Office of Inspector General issued two prior audit reports on the Ypsilanti Housing
Commission. The first report was issued on May 28, 1982 (Audit Report Number 82-CH-202-
1066). The report contained 13 findings. The recommendations for the findings were closed.
Seven of the 13 findings are repeated in this report.

           Audit Report Number 82-CH-202-1066                        This Report
      PHA’s Vacancy Losses Exceed HUD’s Limits            The Commission Needs To Reduce
                     (Finding 1).                          High Vacancy Rates (Finding 2).
      Questionable And Unsupported Maintenance             Controls For Safeguarding Assets
                Expenses (Finding 2).                      Need Strengthening (Finding 3).
     Deficiencies In Accounting System (Finding 3).               Same As Above.
      Lack Of Control Over Purchases Of Materials
               And Services (Finding 4).                          Same As Above.
       Weaknesses In Internal Control Over Cash
                 Receipts (Finding 5).                            Same As Above.
       Nonexpendable Equipment Records Were
                Inadequate (Finding 9).                           Same As Above.
     Investment Program Deficiencies (Finding 10).                Same As Above.


The second report was issued on November 30, 1992 (Audit Report Number 93-CH-202-1005).
The report contained four findings. The recommendations for the findings were closed. Two of the
four findings are repeated in this report.

       Audit Report Number 93-CH-202-1005                         This Report
       The Commission Did Not Maintain An          The Commission Needs To Reduce High
      Acceptable Occupancy Level (Finding 2).            Vacancy Rates (Finding 2).
     Controls For Safeguarding Assets Were not        Controls For Safeguarding Assets Need
               Adequate (Finding 3).                        Strengthening (Finding 3).

The latest single audit for the Housing Commission covered the fiscal year ended June 30, 2000.
The report contained one finding, which was not repeated in this report.




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                                                                                        Appendix A

Schedule of Questioned Costs

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

                      1A                             $98,466
                      3E                                                $17,281
                      3F                               3,327
                     Total                          $101,793            $17,281


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




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                                                                                       Appendix B

Auditee Comments
July 20, 2001

Michael A. Raponi
Assistant District Inspector General for
Audit, Midwest
U.S. Department of Housing and Urban Development
Office of the Inspector General
77 West Jackson Blvd., Suite 2646
Chicago, IL 60604-3507

Re: Response to Draft Findings 1 & 2

Dear Mr. Raponi:

This letter is in response to the draft findings of the Ypsilanti Housing Commission. An Audit
has been on-going for the past several months; the Commission has been presented with the first
two of three audit findings. The two findings addressed in this letter are:

1) Commission's Operating Subsidy was Inflated; and
2) Commission's Needs to Reduce High Vacancy Rates.

Upon my request to the Office of Inspector General (OIG) to review the workpapers which
constituted the aforementioned findings, the OIG arranged for a meeting which included the
auditors, HUD staff, the Ypsilanti Housing Commission fee accountant, and myself. OIG
provided copies of all relevant workpapers and answered questions posed by the fee accountant
and myself. I was afforded as much time as necessary to gain a full understanding of the issues
and was granted an extension of time to offer this written response; the auditor and supervisor
conducted the meeting in a professional and courteous manner.

I am the Executive Director of the Ypsilanti Housing Commission, and have been charged with
the responsibility of completing and submitting forms on behalf of the Board of Commissioners.
I make every effort to perform my responsibilities in an accurate and timely manner. I have not
knowingly submitted any document to contain false or misleading information to the
government; however, some documents submitted may have contained errors due to
circumstances beyond my control, out of inadvertence or lack of knowledge of the Rule. I
endeavor to maintain all Rules and Regulations in a manner that I review them upon receipt and
in a special file for reference. Unfortunately, I was unable to locate the vacancy rule in my file.
Considering all of the circumstances, I unequivocally had no knowledge of the Rule.

Specific information concerning the above findings are as follows:




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Operating Subsidy Inflated.

The OIG has established that an overpayment of $98,466.00 in operating subsidy occurred for the
years 1997-2001 as a result of the Commission failing to accurately report the long term
vacancies on HUD form 52723, Calculation of Performance Funding System Operating Subsidy.
The recapitulation of the long term vacancies by the OIG appears to be correct; however, the
explanation of the Directors knowledge is incorrect. In the first paragraph under Subsidy Not
Adjusted for long Term Vacancies, the Draft Finding states, "The Director said she became
aware of the long term vacancy rule when the fee accountant reported the long term vacancy
adjustment for fiscal year 2001. The Director contradicted herself in a subsequent interview when
she said she was unaware of the requirement." OIG claims the exact interview, question and
answer, can be established from the auditors notes which support this statement; however, either
the auditor or I was mistaken concerning the facts; I was absolutely unaware of the required
adjustment until it was questioned by the HUD area office as a result of the submission of the
2001 budget. NO correction has taken place because I was awaiting the results of the OIG audit
which is still not complete.

HUD form 52723 is a complicated form which requires input fro the Commission, HUD, and
Congress, and is not completed until several months after the subjected budget year. Several lines
of information require adjustment after year end when actual data is available. There are 88 lines
of data on the HUD forms 52723 for the years 1997-2001, 67 lines were changed by the HUD
area office not including the lines changed by the OIG. 75% of the submitted data has been
changed by HUD as a result of changes mandated by Congress, HUD, or corrections of errors.
The following represents the requested subsidy as originally presented by the Commission and
the actual subsidy received after the corrections by HUD (prior to the recommended changed by
OIG)

Year End       Requested      Received        (Under)/Over
6/30/97         $364,695      $359,066          $(5,629)
6/30/98        445,147        444,702              (445)
6/30/99        395,366         429,527           34,161
6/30/00        383,573        353,665           (29,908)
6/30/01        398,916        431,756            32,840
               _________      ________        _________
               $1,987,697     $2,018,716        $31,019

I did not have knowledge of the mandatory adjustment for long term vacancies, but in my attempt
to complete HUD form 52723 for the year ended June 30, 1997, I realized that the Commission
had vacancies; I used 90% on line 17, projected occupancy percentage; HUD increased the
percentage to 97%. HUD's adjustment increased the original request by $15,539.

In 1996, the Commission requested permission to demolish 20 units which had fallen in disrepair
and are located in a high crime area; the units had been unrentable. HUD approved the plan in
1998, and in 1999 the units were razed; in reviewing the HUD form 52723, the approving HUD
official did not question the lack of the adjustment for long term vacancies even though having

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full knowledge of the nature of the units. In addition to the missed adjustment for long term
vacancies, both HUD and the Commission failed to adjust the 6/30/97 budget for the FICA
adjustment; obviously HUD realized we had employees subject to FICA; once I became aware of
that rule the adjustment was made for 1997 on the 1998 HUD form 52723, which reveals my
good faith intent to correct known mistakes when information becomes available.

The recommendations by OIG are as follows:

We recommend that the false claims be:

1A     Referred to the United States Attorneys Office for consideration of pursuit under the
       False Claims Act, Title 31 of the United States Code, Section 3729.

1B     De-obligate $23, 472 from the Commission's fiscal year 2001 budget to accurately reflect
       long term vacant units and the number of units occupied.

1C     Recover $74,994 worth of excess subsidy payments made for long term vacancies from
       July 1, 1996 to June 30, 2000.

1D     Pursues administrative Action against the Housing Commission's Executive Director
       based on the continual false certifications as permitted by 24 CFR Part 24.

The Performance Funding System is routinely subjected to corrections and changes; year end
adjustments to Investment Income, audit cost and utility expense levels are made annually. It is
not uncommon to have the initial submission of the budget altered by HUD before a claim is ever
made to the government. Referral to the United States Attorneys' Office under the False Claims
Act is without merit; I did not have actual knowledge of the information (Long Term Vacancy
Adjustment), or act in deliberate ignorance of the truth or falsity of the information; or, act in
reckless disregard or the truth or falsity of the information. Section 3729, False Claims states the
following: (a) Liability for Certain Acts. - Any person who...

My intention is not to impugn dedicated persons who work for the Detroit Area Office, but the
signature which constitutes a claim for the payment is signed by both the representative of the
Commission, and the Authorized Field office Representative; both under the same warning. I
have always maintained a cooperative and willing to adhere to Rules and Regulations
relationship with the HUD office.

The field office had knowledge of the required adjustment for long term vacancies as evidenced
by distributing Public and Indian Housing Notice 96-35 on June 4, 1996. Further, the field office
had knowledge of our long term vacancies because of our request to demolish unrentable units
submitted to HUD in 1997; the field office did not question the lack of adjustment for long term
vacancies, however, did inquire and change 75% of the data submitted. OIG views the 67 lines of
changes to be acceptable as correction of an error, but the line for long term vacancies subject to
referrals as a false claim; when asked to explain the difference, OIG was unable to differentiate


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between acceptable errors and/or a false claim. Accordingly, we submit that the line item for long
term vacancies should also fall in the category of the correction of an error.

The Commission would agree to repay the $98,466 by either de-obligating the funds from the
Commission's 2002 budget, or repayment directly to HUD; in addition, I would welcome
assistance from the Area Office either in the form of on site support or oversight. I do not believe
referrals or administrative actions are necessary under the circumstances; the cost for both the
government and the Commission would be unwarranted and counter productive. Moreover, I
should not be held responsible for the actions of other Commission Directors or the Commission
actions prior to my becoming the Director.

Commission Needs to Reduce High Vacancy Rates

The OIG has documented that the Commission has had a high vacancy rate for several years.
This fact is not being disputed. I do not agree with the statement that I found the vacancy rate to
be acceptable.

The Commission took the following actions to reduce the vacancy rate:

1. Applied for and received funding under the Vacancy Reduction Program, 1994;
2. Requested permission to demolish 20 units at Parkridge Homes, 1997;
3. Requested permission to deprogram 4 units at Parkridge Homes to be used for tenant services,
1997. (The Commission never received any correspondence from field office regarding this
request);
4. Applied for HOPE VI, 1999 (The Commission was not funded under this grant);
5. After HOPE VI was not funded, the Commission continued dialogue with City of Ypsilanti
officials regarding the future of the Parkridge Homes. The issues of high crime and density were
discussed, two factors that make renting these units extremely difficult, 1999 to present; and
6. Collaborated with Eastern Michigan University on various grant applications and projects that
would ultimately have helped with the improvement of the image of the Gateway community,
where the majority of the Commission's units were located, 1995 to present.

There have been several obstacles over the years that have contributed to the Commission's
inability to correct the vacancy problem:
1. Available units are often refused by applicants because of location and lack of amenities, i.e.
Parkridge Homes, due to criminal activity, age of units, lack of space.
2. One-Strike policy requires eviction for criminal and drug related activities. The Commission
has processed a large number of evictions due to this policy. This policy also reduces the number
of eligible applicants.
3. Over the past two years several public housing residents moved out because they received
Section 8.
4. The Commission has not had complete maintenance staff for several years. The reasons
include medical leaves, a transfer to another City department by one maintenance worker, and the
inability to retain a competent supervisor.


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I agree that the controls over the Maintenance Operations are weak. This problem is due in part
to the fact that the department has not had a full time maintenance supervisor. Preparation of a
unit status report for review by the Board could be handled by a maintenance supervisor.
The OIG states that the waiting list was sufficient to fill 29 of 34 vacancies. I do not necessarily
agree with this statement. There is no way to guarantee that every applicant would have been
willing to accept a unit that may have been available at Parkridge Homes.

The recommendations by the OIG are as follows:

We recommend the Michigan State Office Director of Public Housing Hub:

2A.     Assures that Ypsilanti Housing Commission hires a full time maintenance supervisor and
        sufficient staff to reduce the high vacancy rate.

2B.     Assure that Ypsilanti Housing Commission fills vacancies form waiting list.

2C.     Assure that Ypsilanti Housing Commission prepares vacant units for occupancy within an
        average of seven calendar days from the date vacated.

The Commissions would agree to hire a full time maintenance supervisor and sufficient staff to
reduce the high vacancy rate. The Commission will also hire a finance manager to assist in form
preparation, grant writing, and strengthening internal controls. The Commission would agree to
revise its policy concerning the number of days required to prepare vacant units. On average,
seven calendar days is not sufficient. Recommendations from the maintenance supervisor would
be taken into consideration prior to the policy being revised.

In closing, I must reiterate that I had no knowledge of the Vacancy Rule prior to filing the HUD
reports and I did not and will not intentionally file a false report for the purpose of increasing the
subsidy allowance or any other reason.

I want to assure the OIG and the Detroit Field Office that I have given this matter the most
serious consideration. I have been on medical leave during the better part of this audit and have
made every effort to cooperate with the OIG and facilitate resolution of the issues raised.
Morever, it is my intent to correct any and all problems raised by the audit immediately upon my
return.


Respectfully submitted,

/signed/

Janine S. Scott, PHM
Executive Director




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                             Ypsilanti Housing Commission
                            Response to OIG Audit Finding #3


The Ypsilanti Housing Commission’s stated goal is to achieve High Performer status within the
next two to three fiscal years. We will have to make significant improvements in many areas to
accomplish this task. To that end, we are glad that the audit report points out certain areas that
need improvement. However, the Commission disagrees with some of the audit findings,
comments and recommendations.

The Commission disagrees with the opening statement in audit finding number three. The OIG
states “The Ypsilanti Housing Commission did not safeguard its cash and other assets against
possible waste, loss and misuse.” The Commission does have safeguards in place to protect its
cash and other assets from waste, loss or misuse. Missing cash or assets have not been reported
and there are no material weaknesses. The Commission agrees that due to several circumstances
some of the controls may have been less than adequate. The following will outline the steps we
are taking to assure that any perceived weaknesses are addressed and corrected.


                      Cash Receipts and Deposits Not Safeguarded

Bank Deposits not Collateralized:

The Commission has discussed this issue with the bank. A new collateral agreement is being
addressed by the bank’s corporate office. A meeting has been set to review the new agreement to
make sure it is in compliance with section 401 of the Annual Contributions Contract. We will
secure banking services that meet all of our needs.

Depository Agreement not on File:

The Commission and the bank are researching the missing document. The Board passed a
resolution adopting the depository agreement in January 2001. We have been in contact with the
bank ever since the auditor inquired about the agreement. It has been very difficult to get this
matter resolved and future discussion with HUD is warranted.

Investment of Excess Funds:

This issue will be addressed with the bank at the upcoming meeting. Arrangements for HUD
approved investments will be made and in the future all excess funds that are not needed within
ninety (90) days will be invested in compliance with section 401 of the Annual Contributions
Contract. A new Finance Director has been hired; his start date was September 4, 2001. It is his
responsibility to make sure all HUD regulations for cash management are implemented and
followed. The “Required HA Cash Management and Investment Policies and Procedures” has


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been downloaded from the HUD web site. This is being reviewed and necessary adjustments and
improvements in internal controls are being implemented on an ongoing basis.

Deposit of Rents in a Timely Manner:

The Commission asserts that the vast majority of deposits were made in a timely manner. The
new finance director has reviewed and discussed this issue with the staff, the appropriate internal
controls have been implemented and all deposits are being made timely. Policy and procedures
will be formalized in writing by June 2002.


                              Disbursements Not Safeguarded

The OIG suggests that the disbursements were not safeguarded and that management controls
were weak. Conversely, the audit report offers very little support for these statements. The
Commission asserts that disbursements were safeguarded and management controls were
adequate.

Segregation of Duties Over Petty Cash and Check Disbursements

The OIG states that the accounting assistant had complete control over the accounting system
including preparation of the accounting records which could lead to misuse. The assistant did not
have complete control of the accounting system or of its records. The Executive Director
reviewed and supervised activities much of the year and when she was on medical leave there
were still adequate controls in place. The fee accountant prepared many financial records
including bank reconciliations, cash disbursements and financial statements. The Board of
Commissioners were given a detailed record of all disbursements on a monthly basis for their
review. Any other segregation of duty issues has been addressed with the addition of the new
finance director.

Adequate Support for Disbursements

The audit finding implies that not all expenditures are for reasonable operating expenses and
repairs. After reviewing the report, the Commission cannot find any expenditure listed by the
OIG that is not appropriate and reasonable. The report only shows that the auditor could not find
some of the documentation; he does not document any expenditure that is not legitimate. The
Commission states that at the time the listed costs were paid that the proper approval was in
place. We contest the statement that $11,850 of general funds was not used for their intended
purpose. The repairs and services in question were completed and there is nothing in the audit
report that indicates that the money did not go to the named payee or that the services were not
performed. We can support all expenditures. With the addition of new computers, better software
and new personnel; the internal controls and approval process for expenditures will be
restructured and improved. The Commission acknowledges its responsibility for filing and better
record keeping and will improve on its ability to provide a detailed audit trail on demand.


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The statement about the Drug Elimination expenditures being unsupported and not used for their
intended purpose is misleading and incorrect. Again, there is no basis for the statement that these
funds were not used for their intended purpose. We can support all expenditures. The new
internal controls and improved procedures will apply to Drug Elimination Grant expenditures as
well.

Duplicate, Ineligible and Questionable Drug Elimination Grant Expenditures

The report states that some wages and an invoice for signs were funded twice. This was due to a
clerical error. The $2,827 of duplicate entries has been corrected. The Finance Director will
review the Grant for accuracy before it is closed in December 2001. Our new software, internal
controls and procedures will prevent this error in the future.

An ineligible cost of $500 for parking lot repairs was charged to the Grant. This entry has been
corrected. The oversight was due to our shortage of staff. As stated above, new procedures and
staff have been added and the Commission is committed to preventing these errors in the future.

Controls Over Check Disbursements Were Weak

The only support offered for this statement is that three manual checks (written at the same time)
were not recorded in the check register. It does not state in the report how many checks were
looked at or what time frame was reviewed. As stated above, the bank reconciliations were
performed on a monthly basis by the fee accountant who kept our books. Any unrecorded checks
would be detected and recorded through this procedure. It is the Commissions position that
adequate internal controls were and are in place.


                                Equipment Not Safeguarded

The audit report states that equipment was not safeguarded and that computers purchased with
grant money were not used for their intended purpose yet the report offers no support or basis for
this comment. It is our position that all equipment is safeguarded and the computers are being
used for their intended purpose. The grant record keeping requirements are being reviewed and
new procedures will be implemented.

The report also states that the Commission does not complete all physical inventory
reconciliations or keep detailed property records. The report also states it recommends a bi-
annual inventory. It should be noted that HUD requires an annual inventory. It is our position that
some asset inventories have been performed and that the asset records do exist. However, the
Commission does recognize that this is an area we can improve upon. The Finance Director will
be responsible for reviewing the asset procurement and disposal procedures, making sure the
annual asset inventory is completed and reconciled to the general ledger and for improving the
internal controls. The Commission is in the process of updating its software capabilities with
regards to asset tracking. We are also considering going out for bids to have one of the many


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firms that specialize in asset inventories perform ours in 2002. At that time we will review
switching to a bar code system.


                              Procurement Controls Were Weak

The audit report states that procurements were not always conducted in a manner that provides
for full and open competition. The example used in the report is for legal services. The report
states that in calendar year 2000 we paid $16,667 for legal services; it further states that this is in
excess of the $5,000 threshold for getting competitive bids. It is our position that the
procurement policy was and is being followed. The amount of money that will be paid for legal
services during any given year is not known or stated in the contract; therefore we were not in
excess of the $5,000 limit when we contracted for legal services. We feel the best way to set up
this type of service is to know what the hourly rate will be. At the time these services were set up
in 1992 and periodically thereafter we have checked the hourly rate and found it to be acceptable.
We are being charged a discounted rate of $75 per hour and feel this is a very reasonable fee for
legal services. The Commission is very satisfied with our legal representation and would not
want to switch firms at this time. The law firm we use qualifies as a minority business so we
have the added benefit of MBE participation that HUD also stresses.

The procurement policies and procedures will be reviewed and updated if necessary. Additional
staff training is also being planned. This is all part of our ongoing effort to continually improve
our housing commission so we achieve our stated goal of High Performer status.


                     Financial & Administrative Controls Were Weak

The issue raised in this section is budget controls, procedures and cost overruns. The new
Finance Director is responsible for reviewing and improving the budgeting and tracking process.
New software and spreadsheets are already being used for this process. When the new accounting
package is purchased and installed (in January 2002) there will be new management reports that
will allow for better and timelier reporting. One such report will show budget to actual
comparisons for both current month and year to date. Included in the new software is a purchase
order system which will improve our internal controls and approval process. Any potential cost
overruns will be detected well in advance and year end budget revisions, if necessary, will be
made.


                              Controls for Safeguarding Assets

References are made to past audit findings and another statement is made about our cash and
assets not being safeguarded. This is a repeat comment and the issue has already been addressed
earlier in the report, as have our plans for improving on our procedures. It is stated that this is a
continuous problem that has not been fixed. It is our position that our cash and assets have been


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safeguarded and this is not a continuous problem. Again, there are no findings of loss, waste or
misuse.


                                       Recommendations

The Commission has taken the necessary steps to resolve all issues. These items have been
addressed in more detail in the body of our response but a summary of each recommendation
follows:

·   Investing excess funds into HUD approved investment securities. The Commission will
    invest all excess funds in compliance with HUD regulations.

·   Depositing cash receipts in a timely manner. New procedures are in place to make sure all
    deposits are made in a timely manner.

·   Segregating petty cash and disbursement duties so no one person has complete control. With
    the addition of staff there is better segregation of duties.

·   Supporting all purchases with source documents to ensure disbursements were used for their
    intended purposes. New internal controls and procedures are being implemented and a new
    Maintenance Supervisor has been hired.

·   Reconciling all checks and the check register with source documents. This procedure has
    always been in place however we will review our procedures and internal controls.
    Improvements will be made where needed.

·   Maintaining a detailed property ledger and take a bi-annual physical inventory to account for
    all Commission assets. An asset inventory will be taken and reconciled to the general ledger
    on an annual basis. All internal controls relating to asset tracking, additions and deletions will
    be reviewed and improved where needed.

·   Conducting procurements in a manner to provide full and open competition and maintain
    records to support the rational and justification of the procurement decision. Our current
    policy will be reviewed and updated where needed. The addition of staff and ongoing training
    will strengthen these areas.

·   Establishing a system of records to separate accounting activities for grant awards, day care
    center and public housing programs. The addition of new staff, training and new software
    will resolve this issue.

·   Establishing procedures and controls to ensure accounting and financial records are current,
    complete and accurate. The addition of new staff, training and new software will resolve this
    issue.


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·   Preventing expenditures in excess of amounts in approved operating budgets for controlled
    accounts. The addition of new staff, improved internal controls, training and new software
    will resolve this issue.

·   Ensure staff receives training in procedures and controls necessary to safeguard cash and
    other assets against waste, loss and misuse. Improved internal controls are being made and
    staff training is being provided.

·   Collateralize all bank balances that exceed the $100,000 FDIC coverage. A meeting has been
    set with the bank and a new collateral agreement will be implemented.

·   Execute a depository agreement with the bank to give HUD authority over all accounts.
    Ongoing discussions with HUD and the bank will address this issue.

·   Provide documentation to support expenditures or refund $17,281 back to HUD from non-
    HUD sources. Documentation can be provided.

·   Reimburse HUD $3,327 for ineligible and duplicate expenditures from non-HUD sources.
    These items have been corrected therefore no refund is necessary.




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Distribution
Regional Director, Midwest (2)
Acting Senior Community Builder/State Coordinator, Michigan State Office
Director of Public Housing Hub, Michigan State Office (2)
Secretary, S (Room 10000)
Deputy Secretary, SD (Room 10100)
Senior Advisor to Deputy Secretary, SD (Room 10100)
Assistant to the Secretary for White House Liaison, S (Room 10216)
Press Secretary/Senior Communications Advisor to the Secretary, S (Room 10226)
Chief of Staff, S (Room 10000)
Acting Assistant Secretary for Administration, A (Room 10110)
Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120)
Director of Departmental Equal Employment Opportunity, U (Room 2112)
Deputy Chief of Staff for Policy and Programs, S (Room 10214)
Deputy Chief of Staff for Intergovernmental Affairs, S (Room 10214)
Director of Center for Faith-Based and Community Initiatives, K (Room 10184)
Executive Officer for Administrative Operations and Management, S (Room 10220)
General Counsel, C (Room 10110)
Acting Assistant General Counsel, Midwest
Assistant Secretary for Housing-Federal Housing Commissioner, H (Room 9100)
General Deputy Assistant Secretary for Policy Development and Research, R (Room 8100)
Assistant Secretary for Community Planning and Development, D (Room 7100)
President of Government National Mortgage Association, T (Room 6100)
Acting Assistant Secretary for Fair Housing and Equal Opportunity, E (Room 5100)
Assistant Secretary for Public and Indian Housing, P (Room 4100)
General Deputy Assistant Secretary for Public and Indian Housing, P (Room 4100)
Acting Deputy Assistant Secretary for Public Housing Investments, PT (Room 4130)
Deputy Assistant CFO for Financial Management, FM (Room 2206)
Acting Deputy Assistant Secretary for Public and Assisted Housing Delivery, PH (Room 4204A)
Deputy Assistant Secretary for Administration and Budget/CFO, PC (Room 4234)
Audit Liaison Officer for Public and Indian Housing, PF (Room 5156)
Chief Information Officer, Q (Room P8206)
Director of Departmental Operations and Coordination, I (Room 2124)
Chief Financial Officer, F (Room 10234)
Director of Audit Coordination/Departmental Audit Liaison Officer, FMA (Room 2206)
Director of Risk Management, FMR (Room 2214)
CFO Audit Liaison Officer, FMA (Room 2206)
Audit Liaison Officer, 3AFI (2)
Director of Enforcement Center, V (200 Portals Building)
Acting Director of Real Estate Assessment Center, X (1280 Maryland Avenue, SW,
        Suite 800)
Acting Director of Multifamily Assistance Restructuring, Y (4000 Portals Building)
Acquisitions Librarian, Library, AS (Room 8141)
Acting Director of Federal Housing Enterprise Oversight, (1700 G Street NW, Room 4011)
Director of Healthy Homes and Lead Hazard Control, L (3206 Portals Building)

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Chief Executive Officer, S (Room 10220)
Assistant Deputy Secretary for Field Policy and Management, M (Room 7108)
Special Counsel, C (Room 10126)
Director of National Office of Labor Relations, SL (Room 7118)
Senior Advisor, Subcommittee on Criminal Justice, Drug Policy & Human Resources, B 373
        Rayburn House Office Building, Washington DC 20515
The Honorable Fred Thompson, Ranking Member, Committee on Governmental Affairs, 340
        Dirksen Senate Office Building, United States Senate, Washington DC 20510
The Honorable Joseph Lieberman, Chairman, Committee on Governmental Affairs, 706 Hart
        Senate Office Building, United States Senate, Washington DC 20510
The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn
        Building, United States House of Representatives, Washington DC 20515
The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform,
        2204 Rayburn Building, United States House of Representatives, Washington DC 20515
The Honorable John Conyers, Jr., Ranking Member, Judiciary Committee, 669 Federal Building,
        United States House of Representatives, 231 West Lafayette, Detroit, Michigan 48226
Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212, O'Neil House
        Office Building, Washington DC 20515
Associate Director of Housing and Telecommunications Issues, United States General
        Accounting Office, 441 G Street N.W., Room 2T23, Washington DC 20548
Steve Redburn, Chief of Housing Branch, Office of Management and Budget, 725 17th Street,
        N.W., Room 9226, New Executive Office Building, Washington DC 20503
Andy Cochran, House Committee on Financial Services, 2129 Rayburn House Office Building,
        Washington DC 20515
Executive Director, Ypsilanti Housing Commission
President of the Board of Commissioners, Ypsilanti Housing Commission




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