AUDIT REPORT
SAGINAW HOUSING COMMISSION
Low-Income Housing, Section 8 and
Drug Elimination Grant Programs
SAGINAW, MICHIGAN
2001-CH-1003
JANUARY 4, 2001
OFFICE OF AUDIT, MIDWEST
CHICAGO, ILLINOIS
EXIT Table of Contents
Issue Date
January 4, 2001
Audit Case Number
2001-CH-1003
TO: Joann L. Adams, Director, Office of Public Housing, Michigan State Office,
5FPH
/signed/
FROM: Dale L. Chouteau, District Inspector General for Audit, Midwest, 5AGA
SUBJECT: Audit of Saginaw Housing Commission
Low-Income Housing, Section 8 and Drug Elimination Grant Programs
Saginaw, Michigan
We completed an audit of Saginaw Housing Commission. The audit was conducted in response to
a HUD request and a complaint to the OIG Hotline. The objectives of the audit were to determine
whether the Housing Commission operated its programs effectively and in compliance with HUD
requirements and other applicable regulations. Generally, the Housing Commission’s programs
were effectively administered, but we noted problems involving drug elimination grant expenses, a
property disposition transaction, and Section 8 unit inspections that did not comply with HUD
requirements.
The Housing Commission disbursed $19,552 in ineligible and unsupported Drug Elimination Grant
funds, and did not assure that one of its subrecipients properly administered its own drug
elimination program. As a result, grant activity reports submitted to HUD were inaccurate. The
Housing Commission also did not obtain HUD approval before selling a parcel of land, and City of
Saginaw officials appeared to have undisclosed conflicts of interest regarding the property sale.
HUD regulations were violated as a result, and the Housing Commission may not have acted in its
best interests or those of its tenants. In addition, we inspected 18 public housing units and found
278 Housing Quality Standards violations that subjected tenants to hazardous and unhealthy living
conditions.
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, or Ronald
Huritz, Assistant District Inspector General for Audit, at (312) 353-6236, extension 2675.
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Management Memorandum
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2001-CH-1003 Page ii
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Executive Summary
We completed an audit of the Saginaw Housing Commission. The audit resulted from a HUD
request and a complaint to the Hotline. The complainant alleged that the President of the Board of
Commissioners of the Housing Commission created a conflict of interest by voting on matters that
benefited an outside organization of which he was the executive director. The objectives of our
audit were to determine whether the Housing Commission operated its programs effectively and in
compliance with HUD requirements and other applicable regulations. Generally, the Housing
Commission’s programs were effectively administered, but we noted problems involving drug
elimination grant expenses, a property disposition transaction, and Section 8 unit inspections that
did not comply with HUD requirements.
The Housing Commission disbursed $19,552 in ineligible and unsupported Drug Elimination Grant
funds, and did not assure that one of its subrecipients properly administered its own drug
elimination program. As a result, grant activity reports submitted to HUD were inaccurate.
The Housing Commission also did not obtain HUD approval before selling a parcel of land, and
City of Saginaw officials appeared to have undisclosed conflicts of interest regarding the property
sale. HUD regulations were violated as a result, and the Housing Commission may not have acted
in its best interests or those of its tenants. In addition, we inspected 18 public housing units and
found 278 Housing Quality Standards violations that subjected tenants to hazardous and unhealthy
living conditions.
Payroll Costs Were The Housing Commission paid $3,632 in unsupported
Unsupported payroll costs to the Saginaw Police Department for two pay
periods. These costs resulted from patrol services that were
furnished to public housing sites. We determined that the
Housing Commission’s Accounting Department reimbursed
the costs to the police department before discovering that
supporting time records were incomplete.
Scholarships Exceeded Limit The Housing Commission overpaid $3,157 in scholarship
money to subrecipient Delta College for eight public housing
residents. Awards for these residents exceeded the limit of
$500 per individual cited in the Notice of Funding
Availability. The over-payments ranged from $78 to $813.
The Housing Commission informed us that it was not aware
of the $500 limit.
Tenants Organization Had The Saginaw Tenants Organization had weak controls over
Weak Controls Over Its its grant funds. We reviewed 100 percent of the financial
Grant Funds; Disbursed transactions for Drug Elimination Program Year 1997. The
Funds That Should Have Tenants Organization did not keep track of the costs that
Been Returned To HUD were or were not reimbursed to it by the Housing
Commission.
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2001-CH-1003
Executive Summary
The Tenants Organization disbursed checks from its grant-
funded bank account totaling $5,947 after February 1, 1999,
the date on which the Saginaw Housing Commission stopped
funding the Tenants Organization. The disbursements
continued until November 1999, nine months after funding
was stopped. The $5,947 should have been returned to HUD
at the time the Tenants Organization was notified by the
Housing Commission that funding was being stopped, but
the Housing Commission failed to seek repayment of the
funds. The disbursements made after February 1, 1999,
resulted from the Tenant Organization’s poor accountability
for its drug elimination grant activities.
Housing Commission Sold The Housing Commission obtained two appraisals for 2.2
Land Below Fair Market acres of land, but sold the land at the lower appraised value
Value Without HUD of $9,000 without HUD approval and without justifying its
Approval action to the Housing Commission’s Board of Directors.
The former Housing Commission Executive Director
informed us that a Board Member employed by a Saginaw
organization having an interest in the land sale
recommended to the Board that the $9,000 figure be
accepted as the selling price. An Application for
Disposition of Real Property, required to be submitted
along with both appraisals to HUD prior to the land sale,
was submitted six months after the Housing Commission
Board authorized the sale. Only the $9,000 appraisal
accompanied the application. As a result, HUD
requirements were violated, and the Housing Commission
may not have received fair compensation for the property.
Section 8 Units Had Health We inspected 18 public housing units and found 278 health
And Safety Violations and safety violations, 271 of which existed at the time the
Housing Commission performed its own inspections. The
violations primarily involved structure and materials
problems, electrical problems and sanitation issues. The
Housing Commission’s inspector cited only 22 of the 278
violations that were noted by the OIG’s inspector. As a
result of these problems, HUD’s Housing Quality Standards
were violated, and tenants were subjected to living
conditions that were hazardous to their health and safety.
Recommendations We recommended that the Director, Office of Public
Housing, Michigan State Office, assures that the Saginaw
Housing Commission: repays to HUD $3,632 in unsupported
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Introduction
Police Department payroll costs; repays to HUD $3,157 for
scholarship awards that exceeded the $500 individual limit;
implements a system to measure its Drug Elimination Grant
activities; seeks repayment of $5,947 from the Saginaw
Tenants Organization for funds that should have been
returned to HUD; obtains fair market value for the parcel of
land by re-soliciting bids and selling it at no less than the
highest appraised value; and corrects the health and safety
violations in the 18 units we inspected.
Auditee Response To Draft We presented our draft findings to the Housing
Findings Commission during the course of the audit. We held an
exit conference with the Executive Director on November
3, 2000. The Housing Commission provided written
comments to our draft findings, which are included in their
entirety as an Appendix to this report.
In his response to our draft findings, the Housing
Commission’s new Executive Director (appointed on
March 27, 2000) acknowledged that the Housing
Commission had lacked a strategic vision to guide
management and staff toward the achievement of sound
programs and controls. He indicated his belief that in his
seven months of service, the Housing Commission had
begun to strategically plan and improve its operations. He
generally agreed with our recommendations related to
improving grant administration and correcting the health
and safety violations (Findings 1 and 4), and generally
disagreed with the recommendations related to the Tenants
Organization and the sale of the land parcel (Findings 2 and
3).
Excerpts of the comments are included with each finding.
Where appropriate, changes were made to the draft findings
to reflect additional information or clarification resulting
from the exit conference and auditee comments.
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2001-CH-1003
Executive Summary
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2001-CH-1003 EXIT Page vi Table of Contents
Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 The Saginaw Housing Commission Needs To Improve Grant
Administration And Evaluate Its Effectiveness 3
2 The Saginaw Housing Commission Did Not Assure That The
Tenants Organization Properly Administered Its Drug Elimination
Grant 9
3 The Saginaw Housing Commission Did Not Follow HUD
Requirements When It Sold Housing Commission Land 15
4 Section 8 Units Had Health And Safety Violations 23
Management Controls 33
Follow Up On Prior Audits 35
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2001-CH-1003
Table of Contents
Appendices
A Schedule of Questioned Costs 37
B Auditee Comments 39
C Distribution 51
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Introduction
The Saginaw Housing Commission was established in 1947 under the Michigan Housing Act of
1937. The Housing Commission was created to provide and manage decent, safe and sanitary
housing facilities for low income families.
The Housing Commission operates Low Income Housing, Section 8 and Drug Elimination Grant
programs. It manages five high-rise buildings consisting of 492 low income housing units
designated for elderly and disabled residents. An additional 112 single family scattered site units
receive Section 8 rental assistance. Between 1995 and 1997, 365 units comprising two
multifamily developments known as Daniels Heights were demolished due to deteriorating
conditions.
The Low Income Housing Program is designed to promote homeownership opportunities for
families whose annual income does not exceed 80 percent of the median income for the
surrounding community. The Section 8 Rental Assistance Program increases affordable housing
choices for low-income households by allowing families to choose privately owned rental
housing. Families or individuals apply to a local public housing authority or other government
agency for a rental certificate or voucher. The housing authority pays the landlord the difference
between 30 percent of the household’s income and the fair market rent. HUD’s Drug
Elimination Grant Program, in existence since 1988, awards competitive grants to public housing
authorities to reduce drug-related crime in and around public housing sites.
A five-member Board of Commissioners, appointed by the Mayor of Saginaw, is the Housing
Commission’s governing board. The Executive Director is Troy White, and the President of the
Board of Commissioners is Frederick D. Price. The Housing Commission’s official records are
maintained at 1803 Norman Street, Saginaw, Michigan.
Audit Objectives The objectives of the audit were to determine whether the
Housing Commission operated its programs effectively and
in compliance with HUD requirements and other applicable
regulations.
Audit Scope and To achieve our objectives, we interviewed both the former
Methodology and current Saginaw Housing Commission Executive
Directors regarding the Commission’s operations, and other
staff members as necessary. We reviewed Housing
Commission and HUD records, including: subrecipient
monitoring reports, independent audits, budgets and
financial statements, the Housing Commission’s bank
account statements, accounts payable invoices, personnel
records, and minutes of the Board of Directors’ meetings.
We used attribute sampling techniques to test
disbursements that were made during the audit period.
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2001-CH-1003
Introduction
To analyze the disposition of Housing Commission
property, we reviewed Board of Directors’ resolutions and
other correspondence, the Application for Disposition of
Real Property, and appraisal and environmental assessment
reports.
To determine the adequacy of the Housing Commission’s
Section 8 housing unit inspection program, we interviewed
personnel responsible for overseeing the function, and
examined inspection procedures and reports.
Regarding the Housing Commission’s subrecipient,
Saginaw Tenants Organization, we reviewed its funding
and disbursement records, consulting contracts and Board
minutes, and interviewed its management personnel.
The audit, which was conducted in accordance with
generally accepted government auditing standards, covered
the period January 1, 1997, through August 31, 1999. We
extended our audit period as necessary. We performed the
audit between August 16, 1999, and September 30, 2000.
We provided a copy of this report to the Housing
Commission’s Executive Director.
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Finding 1
The Saginaw Housing Commission Needs to
Improve Grant Administration and Evaluate Its
Effectiveness
The Saginaw Housing Commission needs to improve its Drug Elimination Grant administration and
evaluate its effectiveness. The Housing Commission disbursed $6,789 in unallowable costs, and could
not demonstrate the benefit or results of its drug elimination activities. As noted in Finding 2, the
Housing Commission also did not assure that one of its subrecipients properly administered its Drug
Elimination Grant activities. This occurred because the Housing Commission did not execute contracts
with its subrecipients; did not establish controls over its planned expenditures to assure that only eligible
costs were charged to the grants; and did not implement a system for evaluating, monitoring and
reporting program outcomes and benefits. As a result, grant activity reports submitted to HUD were
inaccurate, and HUD could not be assured that the Saginaw Housing Commission met the objective of
the drug elimination program.
Drug Elimination Program The objective of the drug elimination program is to curtail
Objective drug-related crime in and around public housing sites.
Applicants for grant funds must develop a comprehensive
program to eliminate drug-related crime in their
developments. To achieve this desired outcome, sound
management practices must be implemented. Management
must develop a system to measure program effectiveness.
The elements of such a system include the setting of
quantifiable performance standards and a monitoring process
to measure program effectiveness.
HUD Requirements 24 CFR 761.35 establishes that grantees are responsible for
managing the day to day operations of the grant and subgrant
activities. Grantees must monitor grant and subgrant
activities to assure compliance with applicable regulations.
The 1997, 1998 and 1999 Notices of Funding Availability
state that education scholarships may be awarded in amounts
not exceeding $500 per individual award.
24 CFR Part 761.35 (a)(1) requires the Housing Commission
to submit a semi-annual performance report that evaluates
the grantee’s performance against its plan. The report should
include: any change or lack of change in crime statistics or
other indicators drawn from the applicant’s plan assessment
and an explanation of any differences; a discussion of any
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2001-CH-1003
Finding 1
problems encountered in implementing the plan and how
they were addressed; an evaluation of whether the rate of
progress met expectations; a discussion of the grantee’s
efforts in encouraging residents’ participation; and a
description of any other programs that may have been
initiated, expanded or deleted as a result of the plan, with an
identification of the resources and the number of people
involved in the programs and their relation to the plan.
Police Payroll Costs Were The Housing Commission paid $3,632 in unsupported
Unsupported payroll costs to the Saginaw Police Department for pay
periods beginning December 19, 1997, and January 16, 1998.
These costs resulted from police patrol services furnished to
public housing sites. The Housing Commission’s
Accounting Department reimbursed the costs to the police
department before discovering that supporting time records
were incomplete. The Accounting Department made no
attempt to obtain the necessary records or recover the
unsupported payments from the police department.
Scholarships Exceeded Limit The Housing Commission overpaid $3,157 in scholarship
money to subrecipient Delta College for eight public housing
residents. Awards for the eight residents exceeded the limit
of $500 per individual cited in the Notices of Funding
Availability. The over-payments ranged from $78 to $813.
The Housing Commission informed us that it was not aware
of the $500 limit.
Incomplete Performance The Housing Commission submitted semi-annual
Reports performance reports to HUD. However, the narratives
generally lacked one or more of the elements required by the
regulations to evaluate the grantee’s progress in reducing or
eliminating drugs from its developments. The Housing
Commission did not have a plan against which progress
could be evaluated. Progress reports for the 1997 Drug
Elimination Grant contained some elements, including
descriptions of drug prevention services, levels of
participation, and crime statistics for the period. However,
the reports generally did not describe changes in crime
statistics. Reports also did not state whether any of the
activities were successfully completed, whether any
problems were encountered, or whether the rate of progress
met expectations. As a result, the Housing Commission did
not have an adequate system for measuring and evaluating
the accomplishments, benefits and effectiveness of its
2001-CH-1003 EXIT Page 4 Table of Contents
Finding 2
various grant-funded activities, such as those discussed
below:
Computer Learning Center. The semi-annual reports
contained examples of educational activities conducted
during the prior six month period, but there was no
information indicating how many students participated, if
any grade improvements resulted from the activities, or if
there was any effect on school drop outs. There were no
quantifiable goals or measurements of results.
Policing. The semi-annual reports generally showed the total
number of crimes committed in Saginaw and the number of
crimes committed at Housing Commission properties, but
there were no crime reduction goals or outcome measures.
The reports did not demonstrate the extent to which policing
efforts had reduced drug-related crime in the projects. The
Housing Commission had reports of suspected criminal
activity and other details, but did not establish a management
information system to compile, summarize and compare this
information, or to measure the program’s effectiveness in
reducing drug-related crime.
Delta College. The semi-annual reports stated that eight
students were enrolled. However, there were no measurable
goals or outcome measures. There were no indications of
how many students graduated, changes in the employment
rate of program participants, or annual income increases
resulting from the schooling.
As a result, the semi-annual reports were incomplete and HUD
could not be assured that the Saginaw Housing Commission
had met the objective of the drug elimination program.
Auditee Comments Excerpts from the auditee’s comments on our draft finding
follow. Appendix B contains the complete text of the
comments:
Housing Commission staff will contact the Saginaw Police
Department and request the supporting payroll
documentation for the periods beginning December 19, 1997
and January 16, 1998. If the information is not available, the
Housing Commission will request a letter from the Saginaw
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2001-CH-1003
Finding 1
Police Department to verify the specific dates the officer was
on duty.
In September 2000, the scholarship program was
discontinued due to the lack of program goals and exceeding
the limits of funding per individual. The Housing
Commission will repay HUD the overpayment amount of
$3,157 for not following the notice of funding program
guidelines.
The Housing Commission will develop a quantitative
performance evaluation measurement system that
encompasses all of the elements of the Drug Elimination
Grant regulation within 90 days. The new system will be
implemented within 30 days from the completion of the new
evaluation system.
The submission of completed semi-annual reports to HUD
will be achieved through the new reporting requirement to
subgrantees and staff. A quarterly review will be instituted
for all activity under the Drug Elimination funding. The
review will be done through a monthly activity report staff
will be required to submit to the Executive Director for
review and comment. The monthly report will serve as a
guide to determine if program measures are being met.
OIG Evaluation of The auditee’s comments were responsive to our
Auditee Comments recommendations. Discussion of these items at the exit
conference confirmed that the Executive Director was
committed to improving the Housing Commission’s Drug
Elimination Grant reporting.
Recommendations We recommend that the Director, Office of Public Housing,
Michigan State Office, assures that the Saginaw Housing
Commission:
1A. Recovers from the Saginaw Police Department and
repays to HUD $3,632 in unsupported payroll costs,
or obtains time records that support the dollar
amount;
1B. Repays HUD $3,157 for scholarship awards that
exceeded the $500 individual limit;
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Finding 2
1C. Implements a system for measuring the effects of its
Drug Elimination Grant funded activities
encompassing all the elements required by the
regulations; and
1D. Submits complete semi-annual reports to HUD
describing program progress and accomplishments in
sufficient detail to allow HUD to assess the Housing
Commission’s effectiveness in administering the
Drug Elimination Grant Program.
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2001-CH-1003
Finding 1
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Finding 2
The Saginaw Housing Commission Did Not
Assure That The Tenants Organization Properly
Administered Its Drug Elimination Grant
The Saginaw Housing Commission did not assure that the Saginaw Tenants Organization, a grant
subrecipient, properly administered the Outreach portion of the Drug Elimination Grant Program. As a
result, the Tenants Organization: had weak controls over its grant funds; improperly disbursed $5,947 of
grant funds that should have been returned to HUD; did not maintain support for its program
accomplishments; and paid unsupported consultant fees which were not included in the budget approved
by HUD. These conditions occurred because: a Sub-recipient Agreement was not in effect; the Housing
Commission’s Board of Directors did not provide adequate guidance to the Tenants Organization; and
the Tenants Organization staff were not properly trained on accounting and recordkeeping requirements.
Consequently, Drug Elimination Grant funds were not used for their intended purpose, and financial
reports and reports of program accomplishments submitted to HUD were not accurate.
HUD Requirements 24 CFR 85.20 (b)(3) states that subgrantees must maintain
effective control and accountability for all subgrant cash, real
and personal property, and other assets. Subgrantees must
adequately safeguard all such property and must assure that it
is used solely for authorized purposes.
24 CFR 85.20 (b)(6) states that accounting records must be
supported by source documentation such as canceled checks,
paid bills, payrolls, time and attendance records, contract and
subgrant award documents.
24 CFR 761.35 states that Grantees are responsible for
managing the day-to-day operations of grant and subgrant
supported activities. Grantees must monitor grant and
subgrant supported activities to assure compliance with
applicable Federal requirements and that performance goals
are being achieved.
24 CFR 761.35 (d)(1) states that the final accountability
report to close out the grant will be a cumulative summary of
expenditures to date and must indicate the exact balance of
unexpended funds. The Grantee shall remit all Drug
Elimination Program funds, including any unexpended
funds, to HUD.
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2001-CH-1003
Finding 2
24 CFR 961.28 (a)(1) requires that semi-annual and annual
reports of program accomplishments contain detailed
evidence of activities that satisfy program objectives, such
as: expectations of the program; the rate of progress toward
achieving the expectations; efforts in encouraging resident
participation; and an identification of the resources and
number of people involved in the programs.
NOFA Requirements Section (I)(C)(6) of the 1997 Notice of Funding Availability
states that funding is permitted for reasonable, necessary and
justified program costs, such as meals, beverages and
transportation incurred only for prevention programs,
employment training, education and youth activities directly
related to reducing or eliminating drug-related crime.
Section (I)(C)(7) of the Notice states that in order to
implement a HUD-approved activity, the housing authority
must be the grantee, and must enter into a subgrantee
contract with the Resident Organization setting forth: the
amount of funds; applicable terms and conditions; financial
controls; payment schedule; performance and financial report
requirements; special conditions, including sanctions for
violation of the agreement; and monitoring. Expenditures for
activities will not be incurred by the Housing Authority and
funds will not be released by the local HUD Field Office
until the grantee has met all of the above requirements.
OMB Requirements OMB Circular A-122, Attachment B, Paragraph 39a, states
that costs of professional and consultant services rendered by
persons who are members of a particular profession or who
possess a special skill, and who are not officers or employees
of the organization, are allowable when reasonable in
relation to the services rendered and when not contingent
upon recovery of the costs from the Federal government.
OMB Circular A-122, Attachment B, Paragraph 16, states
that costs of fines and penalties resulting from violations of,
or failure of the organization to comply with Federal, State,
and local laws and regulations, are unallowable.
Sub-recipient Agreement Throughout the life of the 1997 Drug Elimination Grant, no
Was Not In Effect sub-recipient agreement existed between the Housing
Commission and the Tenants Organization, as required by
the 1997 Notice of Funding Availability. Housing
Commission personnel advised us that they attempted to
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Finding 2
execute an agreement with the Tenants Organization, but the
Tenants Organization’s management insisted on including
various terms in the agreement that were not acceptable to
the Housing Commission. This led to a stalemate that
resulted in the grant activities being conducted without a
contractual relationship between the parties. HUD disbursed
grant funds to the Housing Commission without being aware
that the required agreement was not in effect.
Tenants Organization Had The Saginaw Tenants Organization had weak controls over
Weak Controls Over Its the way it accounted for its grant funds. We reviewed 100
Grant Funds percent of the financial transactions for Drug Elimination
Program Year 1997. Of $46,083 in grant funds disbursed
between March 6, 1998, and May 7, 1999, the Tenants
Organization failed to keep track of the majority of costs that
were or were not reimbursed to it by the Housing
Commission. As a result, the Tenants Organization was not
assured that its records accurately reflected all disbursement
and reimbursement activity, and the Saginaw Housing
Commission was not assured that Drug Elimination Grant
funds were being used for their intended purpose.
Housing Commission The Housing Commission paid the gross wage amount when
Overpaid Tenants it reimbursed the Tenants Organization for payroll costs.
Organization For Payroll The reimbursed amount included the employee withheld
Taxes portion as well as the employer portion. Only the employer
portion should have been reimbursed. As a result, the
Housing Commission overpaid the Tenants Organization for
payroll taxes and other items by at least $2,466.
Tenants Organization Because of the Tenants Organization’s poor accountability
Disbursed Funds That Should for its Drug Elimination Grant activities, the Housing
Have Been Returned To Commission advised the Tenants Organization that it would
HUD not be reimbursed for any costs incurred after February 1,
1999. The Housing Commission was not aware that the
Tenants Organization had unused grant funds because of
poor communication between the parties caused by tensions
over the subrecipient agreement discussed above. This
caused the Housing Commission to decrease its monitoring
of the Tenants Organization’s financial activity, allowing the
unused funds to go undetected.
The Tenants Organization disbursed checks from its grant-
funded bank account totaling $5,947 after February 1 for
expenses such as telephone bills, payroll, consultant fees,
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2001-CH-1003
Finding 2
Internal Revenue Service taxes and penalties, and insurance
premiums. Some, but not all, of these expenses were incurred
by the Tenants Organization prior to February 1, but all were
paid after that date. The disbursements continued until
November 1999, nine months after funding was stopped.
The funds in the account should have been returned to HUD
at the time the Tenants Organization was notified by the
Housing Commission that funding was being stopped, but
the Housing Commission failed to seek repayment of the
unused funds.
Payroll Taxes And Quarterly The Housing Commission did not assure that the Tenants
Reports Not Submitted Organization paid its payroll taxes on a timely basis. On
Timely several occasions, after being reimbursed by the Housing
Commission, a Tenants Organization accounting clerk
prepared the payroll tax deposit check and placed it in a desk
drawer. The clerk did not submit the check to the Internal
Revenue Service for the calendar quarter it was due;
however, she indicated on the quarterly report submitted to
the Internal Revenue that the taxes were paid. The delays in
submitting the tax payments ranged from 10 days to 296
days. At one point in 1998, the IRS placed a lien against the
Tenant Organization’s checking account in the amount of
$2,148 until the delinquent taxes were paid. We could not
determine the exact amount of penalties and interest that
were assessed by the Internal Revenue Service as a result.
This failure to make timely Federal tax deposits violated
OMB Circular A-122.
Reported Accomplishments The Housing Commission did not assure that the Tenants
Were Not Supported Organization established well-defined goals for its Drug
Elimination Grant activities. The Tenants Organization also
did not have an effective system to determine whether
program objectives were accomplished.
We reviewed the semi-annual and annual progress reports
submitted by the Tenants Organization to HUD for Calendar
Year 1998. Of 57 accomplishments listed in the reports, 50
were not properly supported. The remaining seven items
were supported only with participant sign-in sheets that did
not detail the nature of the accomplishments. HUD
regulations at 24 CFR 961.28 require detailed reporting of
program expectations, the rate of progress toward achieving
the expectations, and activities completed to satisfy the
expectations.
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Finding 2
Consultant Fees Not Included In 1998 and 1999, the Tenants Organization paid fees of
In HUD-Approved Budget $4,350 from 1997 grant funds to an outside financial
consultant. The fees were not included in the budget
approved by HUD. Although the consultant was engaged to
provide a package of accounting and training services for the
organization, we could not locate supporting documentation
to determine the specific deliverables for which the
consultant was paid.
Summary of Questioned The following costs were ineligible expenses under the 1997
Costs Notice of Funding Availability:
• $2,466 – Overpaid by Saginaw Housing
Commission to Saginaw Tenants Organization for
payroll withholding taxes;
• $5,947 – Disbursed after the Drug Elimination
Grant was closed out.
The following costs lacked supporting documentation:
• $4,350 – Paid to financial consultant
Auditee Comments Excerpts from the auditee’s comments on our draft finding
follow. Appendix B contains the complete text of the
comments:
As a subcontractor or subgrantee to the Housing
Commission, the Saginaw Tenants Organization would be
responsible to make all payroll tax payments without any
direction from the Housing Commission. If an overpayment
occurred, it would be the responsibility of the grantee to
repay HUD the funding and seek repayment from the
subgrantee. The Housing Commission’s possible error in the
overpayment will be resolved in reviewing the original
program budget with the Tenants Organization and providing
supporting documentation for the total payroll tax payments.
The Housing Commission informed the Tenants
Organization that no costs incurred after February 1, 1999
would be reimbursable. The Housing Commission
distributed the $5,947 to the Tenants Organization prior to
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2001-CH-1003
Finding 2
the funding restriction. The fact that the Tenants
Organization paid its expenses months later does not
invalidate the funding especially since the Housing
Commission did not seek a lien on the Tenant Organization’s
bank account. I believe these funds should not be repaid to
HUD.
The Housing Commission will request the Saginaw Tenants
Organization to submit all supporting documentation and
deliverables that the Organization received from the
consultant.
OIG Evaluation of At the exit conference, the Director of Public Housing,
Auditee Comments Michigan State Office, indicated to the Housing
Commission’s Executive Director that the Tenants
Organization was a subgrantee, not a subcontractor, and that
it was the Housing Commission’s responsibility to make sure
that the Tenants Organization followed all HUD
requirements.
Because there was no subrecipient agreement in effect
between the Housing Commission and the Tenants
Organization during the time period of the Drug Elimination
Grant, the original budget submitted by the Housing
Commission to HUD was the controlling instrument for
reimbursable payments. The expenses that were paid by the
Tenants Organization after February 1, 1999, were not part of
that budget, and therefore, were not eligible costs allowable
by the Notice of Funding Availability.
Recommendations We recommend the Director, Office of Public Housing,
Michigan State Office, assures that the Saginaw Housing
Commission:
2A. Repays HUD $2,466 for excess payroll withholding
taxes paid by the Housing Commission to the
Saginaw Tenants Organization;
2B. Instructs the Tenants Organization to repay HUD
$5,947 disbursed after February 1, 1999; and
2C. Provides documentation to HUD supporting $4,350
in fees paid to the Tenant Organization’s consultant.
2001-CH-1003 EXIT Page 14 Table of Contents
Finding 2
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2001-CH-1003
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Finding 3
The Saginaw Housing Commission Did Not
Follow HUD Requirements When It Sold
Housing Commission Land
The Saginaw Housing Commission did not get prior HUD approval when it sold 2.2 acres of land
to a developer in August 1999. A legal closing took place for the transaction but the settlement
funds were placed into escrow due to an unresolved contingency. The Housing Commission
ignored HUD regulations by not: submitting to HUD an Application for Disposition of Public
Housing property prior to sale of the land; performing an environmental assessment in accordance
with environmental regulations before taking an action committing HUD or local funds; and
obtaining HUD approval before disposing of the land at less than fair market value.
This activity occurred, in part, because the Housing Commission had not developed a formal long
range revitalization plan for the area encompassing the 2.2 acre parcel, formerly known as the
Daniels Heights Public Housing site. Such a plan would have disclosed if the land was to be
disposed of or retained for future development. Also, Housing Commission Board members
approved a resolution disposing of the property without conducting research into HUD disposition
requirements. Further, some Board members appeared to have conflicts of interest between the
Housing Commission and their private employers, who, along with the City of Saginaw, would
have benefited from the land sale. Consequently, the Housing Commission: (1) may not have
acted in the best interests of the Housing Commission and its tenants; (2) did not obtain an
impartial environmental assessment as required; and (3) did not receive fair compensation for the
property it attempted to sell.
HUD Regulations HUD Regulations at 24 CFR Part 970.8 require written
approval by HUD before the Housing Commission may
undertake any transaction involving disposition of real
property. The Housing Commission must submit an
application to the appropriate HUD Office with various
documentation justifying the proposed disposition to allow
HUD to determine what is in the best interests of the tenants
and the Housing Commission.
24 CFR Part 970.4 and 24 CFR Part 50 require that the
disposition meet Environmental Review Regulations and
prohibits acquiring, rehabilitating, converting, leasing,
repairing or constructing property or committing HUD or
local funds to the activity until HUD approval is obtained.
24 CFR Part 970.9(a) requires the Housing Commission to
dispose of real estate promptly by soliciting bids at fair
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2001-CH-1003
Finding 3
market value unless HUD authorizes a negotiated sale for
reasons in the best interests of the Housing Commission or
the Federal Government.
Annual Contributions A Comprehensive Grant Program Amendment dated October
Contract 19, 1998, to the Consolidated Annual Contributions Contract
Paragraph 5, requires the Housing Commission to continue
to operate each development as low-income housing in
compliance with the Annual Contributions Contract and all
HUD regulations for a period of 20 years after the last
disbursement of comprehensive grant assistance.
Furthermore, no disposition of any development covered by
the amendment can occur for a period of ten years following
the last payment of operating subsidy unless approved by
HUD.
Disposition Application The Saginaw Housing Commission sold a 2.2-acre parcel of
Submitted To HUD After vacant land in August 1999. The parcel was part of the
Land Was Sold former Daniels Heights Development, a public housing site
in northeast Saginaw, Michigan, that was demolished in
1997. The Housing Commission’s Board approved the
disposition of this parcel of land in Board Resolution 99-04
on June 23, 1999. The Purchase Agreement, originally
prepared in June, was executed and signed on August 3,
1999. The closing date was identified as August 13, 1999.
The sale price was $9,000 with a deposit of $1,000 dated
June 17, 1999, from the buyer, K-Properties Leasing, LLC.
After the closing, a warranty deed transferring ownership of
the land was executed on September 1, 1999, and given to
Lawyers Title Insurance Company. However, the title
transfer was not recorded by the Saginaw County Registrar
of Deeds because the title company identified unpaid bonds
in a Declaration of Trust that needed to be resolved first.
Thus, a closing took place but all documents were held in
trust by the title company and the settlement funds were
placed in escrow until the condition cited by the title
company could be resolved. This situation has remained
unresolved as of December 15, 2000.
HUD approval for the disposition of the land was not
formally requested until the Housing Commission submitted
an Application for Disposition of Real Property on
December 15, 1999, to HUD’s Special Applications Center.
This action was nearly six months after the Housing
Commission Board approved its resolution to dispose of the
2001-CH-1003 EXIT Page 18 Table of Contents
Finding 3
site. Prior HUD approval is required by Title 24 Part 970
regulations regarding disposition of real property. By selling
the land without HUD approval, the Housing Commission
also violated its obligation under the Annual Contributions
Contract to operate the property as low-income housing. As
of August 2000, the Application for Disposition of Real
Property was still pending HUD approval.
Environmental The 2.2 acre tract is one of three parcels on which
Assessment Prepared manufacturing plants for two new General Motors suppliers
After The Sale Closed were planned to be built. The two plants, financed with $6.7
million in revenue bonds issued through Saginaw County’s
Economic Development Corporation, have already been
constructed on the other two parcels. No construction has
started on the 2.2 acre site pending HUD approval of the
sale. All three parcels were purchased by the same
developer.
A Phase I Environmental Site Assessment Report covering
all three parcels was issued June 21, 1999, and a Phase II
Environmental Site Assessment Report covering the same
parcels was issued August 25, 1999. However, the Housing
Commission did not submit its completed environmental
assessment to the Detroit HUD Office in compliance with
HUD’s environmental regulations until about April 14, 2000.
As indicated earlier, the closing took place on August 13,
1999, and the warranty deed between the Housing
Commission and the buyer was signed on September 1,
1999. These dates passed before the Housing Commission
completed its environmental assessment. Consequently, the
Housing Commission failed to comply with the
environmental requirements because it sold the land before
the environmental assessment report was completed.
The environmental assessment was not prepared prior to the
sale because of confusion over who had responsibility for the
activity. The Saginaw Housing Commission expected the
City to perform the assessment; the City expected HUD to
perform the assessment. Responsibility for this activity
shifted from HUD to the City as a result of a change in the
Federal Regulations that became effective May 30, 1996.
HUD decided in February 2000 to allow the Housing
Commission to contract out this activity since neither the
City nor the Housing Commission had the time or expertise
to conduct the assessment in house.
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2001-CH-1003
Finding 3
Land Was Sold At Less The Housing Commission obtained two independent
Than Fair Market Value appraisals for the subject parcel in July 1999. The first
appraisal was for $9,000; the second was for $13,250. The
appraisals were prepared on July 12 and July 16,
respectively. The second appraisal was more extensive and
was based on six comparable sales while the first appraisal
was based on only three comparable sales.
The Housing Commission established $9,000 as the sale
price for its parcel based on the lower of the two appraisals
without giving any justification to the Housing
Commission’s Board. We examined the Board Meeting
Minutes and Board Advisories covering the period May
through September of 1999 but could not locate any
references to the property being sold for less than fair market
value. The former Executive Director informed us that the
Board Member employed by Saginaw Future, Inc.
recommended that the $9,000 figure be accepted as the
selling price.
HUD Regulations at 24 CFR Part 970.8 describe what
documents must be included in the Housing Commission’s
application seeking HUD approval. Part 970.8(l) requires an
estimate of fair market value for the property, established on
the basis of one independent appraisal, unless HUD
determines that more than one appraisal is warranted. In this
case, HUD’s Grand Rapids Office requested two
independent appraisals, according to statements made by the
Executive Director in the Board Minutes of July 26, 1999.
However, the second appraisal that resulted in a higher
valuation for the property was apparently ignored by the
Housing Commission. HUD files indicated that only the
$9,000 appraisal was received with the Application for
Disposition of Real Property, preventing HUD from
considering the higher valuation.
Board Members And The The Saginaw Housing Commission Board consists of five
Mayor Had Undisclosed members appointed by the Mayor of the City of Saginaw to
Conflicts Of Interest staggered five year terms. At least two of the Board
Members and the Mayor appeared to have conflicts of
interest because the property sale would have benefited one
or more General Motors suppliers. One of the members
works for Saginaw Future, Inc., the agency responsible for
initiating the idea of attracting companies to Saginaw with an
interest in building new facilities in close proximity to
2001-CH-1003 EXIT Page 20 Table of Contents
Finding 3
General Motors. The other Board Member and the Mayor of
Saginaw are both employed by Delphi Automotive, a major
supplier that was part of General Motors until it was spun off
as an independent company in 1999.
Based on our review of Board Minutes, we concluded that
neither Board member disclosed their potential conflict of
interest during the Board Meeting at which Resolution 99-04
was passed that authorized the land sale. Neither Board
member abstained from voting on the resolution. The
Minutes do not reflect that the $9,000 selling price was voted
on by the Board, or that the price was advocated by a
particular Board member.
Since the Mayor of Saginaw appoints the Board Members,
and the Mayor and the Board Members in question work for
a General Motors supplier and an organization promoting
business for General Motors suppliers, there is an appearance
that the disposition of the land may not have been in the best
interests of the Housing Commission. The transaction would
have primarily benefited the City of Saginaw.
Conclusion The Saginaw Housing Commission ignored HUD’s Part 970
Regulations by: (1) not preparing an application to HUD for
disposition of public housing property prior to selling the
land; (2) not performing an environmental assessment in
accordance with the environmental regulations before taking
an action committing HUD or local funds; and (3) failing to
obtain HUD approval before selling the land at less than fair
market value. Board members approved a resolution
authorizing the sale of the property without conducting
research into HUD’s disposition requirements. Furthermore,
conflict of interest relationships existed between some
Board members and their private employers that appeared to
influence the decision to sell the property for less than fair
market value before the environmental assessment was
completed.
Consequently, an impartial environmental assessment could
not be prepared, the disposition action may not have been in
the best interests of the Housing Commission, and fair
compensation for the property was not assured.
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2001-CH-1003
Finding 3
Auditee Comments Excerpts from the auditee’s comments on our draft finding
follow. Appendix B contains the complete text of the
comments:
Under a previous administration, the Housing Commission
started the disposition process for the 2.2 acres of land
without regard to HUD regulations that are very clear about
disposition of property. A security deposit for the property in
the amount of $1,000 was issued and held by the Housing
Commission. However, a formal closing did not take place
because of the unpaid bond on the land. A closing cannot
take place when land has not been legally cleared of all
obligations. As a result, the signed warranty transfer was not
valid.
The Housing Commission did comply with the
environmental requirements because the land was never
legally transferred or sold.
I disagree that two Board Members and the Mayor had
undisclosed conflicts of interest. The fact that the Board
Members and Mayor were advocating for the selling of the
property to increase economic opportunity for the residents
of the City of Saginaw does not constitute a conflict of
interest in my opinion. The appearance and actual conflict of
interest are two vastly different issues. The Mayor and
Board Member that work for a General Motors supplier did
not benefit directly or indirectly from the transaction. As the
Executive Director, I will assure HUD that the Housing
Commission has and will take all necessary safeguards to
ensure compliance of regulations and address conflicts of
interest.
OIG Evaluation of A formal closing did occur at Lawyer’s Title Insurance
Auditee Comments Company on August 13, 1999. Documents were signed
acknowledging the legal requirements needed before the
closing could be recorded at the Saginaw County Registrar of
Deeds Office. Thus, a closing did take place but it could not
be legally recorded until the conditions cited by the title
company were removed.
The environmental requirements at 24 CFR Part 970.4
prohibit any disposition activity committing HUD or local
funds to the activity until HUD approval is obtained. The
2001-CH-1003 EXIT Page 22 Table of Contents
Finding 3
purchase agreement for the land was executed on August 3,
1999. A lease was executed between the Housing
Commission and the purchaser in January 2000. Both
actions took place before the environmental review was
completed. These activities show that the Housing
Commission did not comply with the environmental
requirements even if the Housing Commission disagrees that
a closing for the land took place on August 13, 1999.
Conflict of interest disclosure requirements cover both actual
and apparent conflicts. The Mayor and two Board Members
should have disclosed their interest in the land sale to the rest
of the Board and the public. We disagree with the Executive
Director that the Board Member employed by Saginaw
Future, Inc. did not benefit indirectly from the land sale.
Without the sale, there would not have been two
manufacturing plants built in the area, and Saginaw County’s
Economic Development Corporation would not have
financed part of the construction with $6.7 million in revenue
bonds. Since securing jobs had been a major concern for the
City, the sale of the land would have benefited General
Motors by having its suppliers nearby. Actions that
benefited the community may have influenced the Mayor to
re-appoint the Board Members to another five-year term.
Recommendations We recommend that the Director, Public Housing, Michigan
State Office, assures that the Saginaw Housing Commission:
3A. Considers taking appropriate action against Board
members for not disclosing potential conflicts of
interest to the full Board and for authorizing
disposition of Housing Commission land without
ensuring that HUD requirements were followed.
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2001-CH-1003
Finding 3
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2001-CH-1003 EXIT Page 24 Table of Contents
Finding 4
Section 8 Units Had Health and Safety
Violations
The Saginaw Housing Commission’s Section 8 units contained numerous health and safety violations.
The 18 units inspected by OIG’s Inspector had a total of 278 violations, 271 of which existed at the time
of the Housing Commission’s last inspection. These deficiencies existed because: the Housing
Commission’s contract inspector did not properly report violations; the Housing Commission did not
consistently do quality control inspections to evaluate the performance of its contracted inspector; the
Housing Commission did not remove landlords from the program who consistently had units with large
numbers of Housing Quality Standards violations; and the Housing Commission did not remove tenants
from the program who abused their units. As a result, HUD’s Housing Quality Standards were violated,
and tenants were subjected to conditions that were hazardous to their health and safety.
HUD Requirements 24 CFR Part 982.1(a) requires that Section 8 dwelling units
be decent, safe and sanitary.
24 CFR Part 982.401(a)(1) says that Section 8 housing must
comply with the Housing Quality Standards, both at initial
occupancy of the dwelling unit, and during the term of the
assisted lease.
24 CFR Part 982.404 says that a family [occupying the unit]
is responsible for a breach of the Housing Quality Standards
that is caused by any member of the household or guest
damaging the dwelling unit or premises (damages beyond
ordinary wear and tear). If the family has caused a breach of
the quality standards, the public housing authority must take
prompt and vigorous action to enforce the family obligations,
which may include terminating assistance for the family.
The Housing Quality Standards address 13 conditions:
• Sanitary Facilities
• Food Preparation and Refuse Disposal
• Space and Security
• Thermal Environment
• Illumination and Electricity
• Structure and Materials
• Interior Air Quality
• Water Supply
• Lead-based Paint
• Access
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2001-CH-1003
Finding 4
• Site and Neighborhood
• Sanitary Conditions
• Smoke Detectors
Sample Selection and We judgmentally selected units for inspection from a total
Inspections universe of 318 units. Of the 318 units, our sample selection
was limited to the same 13 units that had been inspected by
the Housing Commission between October 1999 and
February 2000. We expanded our scope to include five
additional units inspected by the Housing Commission
during the same time period that were identified to us as
having landlords with a history of repeat quality standards
violations. Our inspections were conducted between March
15 and March 22, 2000. We provided photographs of the
units and copies of the inspection reports to the Housing
Commission’s Section 8 Manager.
Units Contained Health and Of the 18 units we inspected, all had health and safety
Safety Violations violations. OIG’s inspector determined that 271 of the 278
violations he observed existed at the time of the Housing
Commission’s last inspection. The Housing Commission’s
inspector identified only 22 of the violations in his reports.
The following is a list of the violations by category of
Housing Quality Standard:
HOUSING QUALITY Violations Percent of Identifie
STANDARD Found Total d by
SHC
Structure and Materials 120 43.17% 8
Illumination and Electricity 53 19.06% 0
Sanitary Bathroom Facilities 19 6.83% 3
Site and Neighborhood 19 6.83% 1
Food Preparation and Refuse 17 6.12% 1
Disposal
Lead-based Paint 15 5.40% 0
Interior Air Supply 11 3.96% 2
Space and Security 10 3.60% 0
Thermal Environment 4 1.44% 2
Access 4 1.44% 0
Smoke Detectors 4 1.44% 1
Water Supply 1 0.36% 4
Sanitary Conditions(pest free) 1 0.36% 0
TOTALS 278 100.00% 22
Structures and Materials In the Structures and Materials category, 120 violations were
identified in 18 units. Violations included air infiltration due
2001-CH-1003 EXIT Page 26 Table of Contents
Appendix B
to windows and exterior doors not fitting properly, rotted
window trim, torn carpet, chimney mortar missing, broken
windows, foundations with severe cracks, unsafe stoop steps,
and deteriorated floors.
To satisfy this standard, the unit must be structurally sound.
The structure must not present any threat to the health and
safety of the occupants and must protect the occupants from
the environment.
Foundation has a large horizontal crack
at 2615 Prescott. This condition existed
during the Housing Commission’s last
inspection.
Foundation is severely cracked and a
few inches out of alignment at 2126
Collingwood. This condition existed
during the Housing Commission’s last
inspection.
Illumination and Electricity Twelve units had 53 illumination and electricity violations.
The violations included missing and broken outlet covers,
exposed electrical wiring, a bedroom not having a ceiling
fixture controlled by a wall switch or a wall outlet controlled
by a wall switch, a kitchen did not have a permanent light
fixture operated by a wall switch. Kitchen and bathroom
outlets were not protected by Ground Fault Circuit
Interrupters.
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2001-CH-1003
Finding 4
HUD regulations require that each room have adequate
natural or artificial illumination to permit normal indoor
activities and support the health and safety of occupants.
Sufficient electrical sources must be provided to permit the
use of essential electrical appliances while assuring safety
from fire. Fires and electrical shock can result from
inadequate or improperly installed electrical facilities.
Although ground fault protected outlets are not a requirement
under HUD’s Housing Quality Standards, they are required
by the City of Saginaw Housing Code, the Consumer
Product Safety Commission and the National Electrical
Code.
Basement at 717 North Fayette has
many electrical hazards.
Sanitary Bathroom Facilities Eleven units had 19 Sanitary Bathroom Facilities violations.
The violations included lack of privacy due to missing
bathroom door hardware, toilets leaking at the base, and
basins and tubs not in proper operating condition.
HUD Regulations require that the dwelling unit must include
sanitary facilities located in the unit and the facilities must be
usable in privacy. The regulations also require that the
dwelling unit have a fixed basin, shower or tub in proper
operating condition with hot and cold running water.
2001-CH-1003 EXIT Page 28 Table of Contents
Appendix B
Bathroom toilet leaking at the base at
2414 Narloch Street
Site and Neighborhood Twelve units had 19 violations in Site and Neighborhood.
Violations included standard one-hour fire-rated door
missing from an unfinished mechanical room next to the
finished living area, and hot water pipes in the living area not
insulated to protect children from burns.
HUD regulations require that site and neighborhood may not
be subject to serious adverse environmental conditions,
natural or manmade, such as dangerous walks or steps,
instability, flooding, poor drainage, septic tank backups or
sewage hazards, excessive accumulations of trash, vermin or
rodent infestation, or fire hazards.
Exposed hot water pipe in the living
area (arrow) is not insulated to
protect children from burns at 1531
Cornelia Street
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2001-CH-1003
Finding 4
Food Preparation And Refuse Nine units had 17 Food Preparation violations. The
Disposal violations included inoperable appliances, missing
refrigerator parts causing food to not maintain a low enough
temperature, and dripping faucets.
HUD Regulations require that the dwelling unit must have
suitable space and equipment to store, prepare and serve
foods in a sanitary manner.
Lead Based Paint Eight units had 15 violations in Lead Based Paint. HUD’s
Housing Quality Standards state that lead-based paint is a
serious health hazard to small children living in older
structures. All chewable, protruding, painted surfaces up to
five feet from the floor or ground which are readily
accessible to children under six years of age and have
cracking, chipping, peeling or loose surfaces may contain
harmful amounts of lead-based paint. All chewable surfaces
must be tested and if lead-based paint is found, the surfaces
must be treated.
Interior Air Supply Seven units had 11 Interior Air Supply violations. They
included water flue pipe severely pinched, plumbing sewer
clean out cap missing, open sewer lines not properly capped,
water heater and furnace room not properly ventilated, and
bath vent fan inoperative.
HUD Regulations require that the dwelling unit must be free
from dangerous levels of air pollution from carbon
monoxide, sewer fuel gas, dust and other harmful pollutants.
Plumbing sewer clean-out cap
is missing at 1531 Cornelia. Sewer
gas is permeating the unit.
2001-CH-1003 EXIT Page 30 Table of Contents
Appendix B
Space and Security Five units had 10 violations related to Space and Security.
The violations included missing and non-functional locks on
windows and doors.
All windows and doors that are accessible from the outside
must be lockable to reduce the risk of burglary or other
unlawful entry into the dwelling. The following picture
shows that a bedroom window accessible from the outside
was missing the locking mechanism. A mother and her two
young daughters lived in the unit.
Bedroom window with exterior access
is missing a locking mechanism.
Contract Inspector Failed To The Housing Commission’s Contract Inspector failed to
Cite Violations properly cite violations. OIG determined that 271 of the
violations identified during our inspections existed at the
time of the Housing Commission’s last inspection. We
based this conclusion on information received from tenants
in relation to the nature of the violations. Of the 18 units
failed by OIG, all 18 were passed by the Housing
Commission inspector.
Excessive Inspections In The Housing Commission entered into an agreement on
Narrow Time Frame April 1, 1997, with a contractor to perform Housing Quality
Standard inspections. He was to perform initial and annual
inspections, and quality control audits of units requested by
the Section 8 Coordinator or the Administrator of Housing
Operations. The contractor received $35.00 per completed
inspection which included a follow-up inspection verifying
that all deficiencies had been corrected.
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2001-CH-1003
Finding 4
In reviewing a billing submitted by the contractor, we noted
that he performed 15 follow-up inspections on August 11,
1999, 26 follow-up and four initial/annual inspections on
August 18, 1999, 24 follow-up inspections on August 19,
1999, 25 initial/annual inspections on August 20, 1999, and
16 initial/annual inspections on August 24, 1999. The
inspector operates as a single individual, not as part of a
larger staff that might have been able to accomplish the
number of inspections billed. According to a HUD official,
it was unlikely that the inspector could complete as many as
25 inspections in one day. Tenants advised us that the
inspector spent very little time in their units. He asked
tenants if there were any known problems.
Quality Control Inspections The Housing Commission did not consistently perform
Not Consistently Performed quality control inspections to evaluate the performance of its
contracted inspector. The Commission’s Section 8 housing
manager informed us that one contracted inspector
performed quality control inspections on units inspected by a
second contracted inspector, but we were unable to confirm
this. The Housing Commission did not have documentation
to support those quality control inspections. Therefore, the
Housing Commission had no assurance that its inspection
program for Section 8 units was adequate or that deficiencies
were properly cited and corrected.
Landlords Not Terminated The Housing Commission has not terminated landlords who
have a history of units that did not pass HUD’s Housing
Quality Standards. However, the Housing Commission has
denied housing assistance payments to some landlords until
the deficiencies were corrected.
When landlords sign the Housing Assistance Payment
Contract, they certify that they will maintain the unit in
accordance with Housing Quality Standards. The Housing
Commission may terminate a Housing Assistance Payment
contract for a breach of the Housing Quality Standards.
Tenants Not Terminated The Housing Commission has not terminated tenants who
have violated the Housing Quality Standards, as provided in
24 CFR Part 982.404. The Housing Commission has denied
tenants access to the program if the tenants owed money to a
landlord, but when they paid what was owed, they were
allowed to continue with the program. However, the Housing
2001-CH-1003 EXIT Page 32 Table of Contents
Appendix B
Commission took no action against tenants who failed to
correct housing violations for which they were responsible.
Thirty six of the 278 violations cited were the responsibility
of the tenant to correct. In all, 13 tenants were cited for one
or more violations.
As a result of the problems detailed above, HUD’s Housing
Quality Standards were violated, and tenants were subjected
to conditions that were hazardous to their health and safety.
Auditee Comments Excerpts from the auditee’s comments on our draft finding
follow. Appendix B contains the complete text of the
comments:
After reviewing this section, it is clear that the Housing
Commission needs to improve the inspection process for all
of its Section 8 Certificate and Voucher holders. I agree with
the report that the inspection of properties has been a weak
link in the program. The 18 Section 8 units will be re-
inspected by the Housing Commission’s staff inspector to
determine if the violations in the report have been repaired.
If the landlord has not made repairs, the inspector will issue a
letter indicating the items that need to be repaired and a
reasonable time period to make them. If all repairs are not
completed in the allotted time, the Housing Commission will
stop housing assistance payments to the landlord(s). The
contract inspector’s services were discontinued during the
audit, and we began utilizing a staff member familiar with
the Housing Quality Standards inspection protocol.
OIG Evaluation of The auditee’s comments were responsive to our
Auditee Comments recommendations.
Recommendations We recommend that the Director, Office of Public Housing
Hub, Michigan State Office, in coordination with the
Michigan State Office’s Director of Community Planning
and Development, assures that the Saginaw Housing
Commission:
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2001-CH-1003
Finding 4
4A. Advises property owners to correct the deficiencies in
the 18 Section 8 units where we identified violations;
4B. Ensures that its contract or internal inspectors receive
sufficient training on HUD inspection procedures to
assure that violations noted during their inspections
are reported in compliance with HUD reporting
requirements; and
4C. Establishes and maintains an effective quality control
system to evaluate the performance of its inspectors.
2001-CH-1003 EXIT Page 34 Table of Contents
Management Controls
In planning and performing our audit, we considered the management controls of the Saginaw
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.
Relevant Management We determined the following management controls were
Controls relevant to our audit objectives:
· 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.
Significant Weaknesses Based on our review, we believe the following items are
significant weaknesses:
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2001-CH-1003
Management Controls
· Program Operations
The Housing Commission’s controls did not ensure that a
system was established for evaluating, monitoring and
reporting Drug Elimination Grant Program outcomes and
benefits. (See Finding 1.) Also, controls did not ensure that
landlords who had a repeat history of housing quality
standards violations, and tenants who abused their living
units, were removed from the housing subsidy program.
(See Finding 4.)
· Compliance with Laws and Regulations
The Housing Commission did not exercise adequate control
over its planned expenditures to assure that only eligible
costs were charged to its grant programs. (See Finding 1.)
Also, controls were inadequate to assure that HUD
requirements were met regarding the need to submit an
Application for Disposition of Real Property and
environmental assessment report before attempting to sell the
2.2-acre parcel of land. (See Finding 3.)
2001-CH-1003 EXIT Page 36 Table of Contents
Follow Up On Prior Audits
This is the first audit conducted by the HUD Office of Inspector General of the Saginaw Housing
Commission in at least the past eight years.
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2001-CH-1003
Follow Up On Prior Audits
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2001-CH-1003 EXIT Page 38 Table of Contents
Appendix A
Schedule of Questioned Costs
Recommendation Type of Questioned Costs
Number Ineligible 1/ Unsupported 2/
1A $3,632
1B $ 3,157
2A 2,466
2B 5,947
2C _______ 4,350
Total $11,570 $7,982
1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
that the auditor believes are not allowable by law, contract or Federal, State or local
policies or regulations.
2/ Unsupported costs are costs charged to a HUD-financed or HUD-insured program or
activity and eligibility cannot be determined at the time of audit. The costs are not
supported by adequate documentation or there is a need for a legal or administrative
determination on the eligibility of the costs. Unsupported costs require a future decision
by HUD program officials. This decision, in addition to obtaining supporting
documentation, might involve a legal interpretation or clarification of Departmental
policies and procedures.
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2001-CH-1003
Appendix A
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2001-CH-1003
Appendix B
Auditee Comments
Saginaw Housing Commission
October 30, 2000
Mr. Ronald F. Huritz
Assistant District Inspector General for Audit
U. S. Department of Housing and Urban Development
Office of Inspector General
77 West Jackson Boulevard, Room 2646
Chicago, IL 60604
Dear Mr. Huritz:
Enclosed are my comments to the Draft Audit Findings at the Saginaw Housing Commission. I
have been the new Executive Director since March 27, 2000, and I have taken some actions prior to
the completion of the audit to improve program management, provide more staff accountability,
and improve the delivery of services. Although the Saginaw Housing Commission has been a
standard performing agency over the past three years under PHMAP, the Housing Commission has
lacked a strategic vision to guide management and staff toward the achievement of sound programs
with controls. In my short seven months, the Housing Commission has begun to not only
strategically plan but also more importantly, improve.
Should you have any questions, please do not hesitate to contact me at (517) 755-8183, extension
137.
Sincerely,
Troy D. White
Executive Director
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2001-CH-1003
Appendix C
Saginaw Housing Commission Needs to
Improve Grant Administration and Evaluate
its Effectiveness
Finding 1
Police Payroll Cost
Were Unsupported It is my understanding from speaking to staff that cross
communication between divisions was extremely poor
between December 1997 and January 1998. The lack of
consistent cross dialog with the various departments caused
poor program management. However, I disagree that the
accounting department made no attempts to obtain the
supporting documentation from the Saginaw Police
Department. The accounting department contacted the
housing operations department responsible for program
management of all social service funds. The accounting
department paid the billing based on the information
submitted. Since my arrival as Executive Director, the
payment structure has been changed.
Scholarships Exceed
Limits I agree with this finding. The Housing Commission did not
follow the HUD notice of funding available which clearly
states that scholarships are not to exceed $500.00 per
individual.
Incomplete Performance
Reports I agree that the semi-annual performance reports need to
improve in terms of measurable quantifiable outcomes for
each program. Unfortunately, under another administration
the Housing Commission did not provide specific
performance measures for programs funded under Drug
Elimination. The information on file does not provide true
program measures because staff was not required to be
responsible to measure program performance.
The Computer Learning Center, Policing, and Delta College
reporting is lacking detail on program outcomes that should
be included in the semi-annual reports.
2001-CH-1003 EXIT Page 42 Table of Contents
Appendix B
Recommendations
Office Of Inspector General
1A. Recover from the Saginaw Police Department and repay to HUD $3,632 in
unsupported payroll cost, or obtain time records that support the dollar amount.
Housing Commission staff will contact the Saginaw Police Department and request the
supporting payroll documentation for the period beginning December 19, 1997 and
January 16, 1998. If the information is not available the Housing Commission will
request a letter from the Saginaw Police Department, Chief of Police, to verify the
specific dates the officer was on duty.
Currently, the billing for the Saginaw Police Department is reviewed and approved by
the Resident Initiative Coordinator. The documentation is sent over to the Administrator
of Business Operations for review and approval. Payments are recorded on the
computer system and presented to the Executive Director in weekly payment reviews.
As of November 6, 2000 the process will be changed as follows; the billing for he
Saginaw Police Department will be reviewed and approved by the Resident Initiative
Coordinator, the supporting documentation will be sent over to the Accounting
Coordinator for review and approval. The Accounting Coordinator will review all
Supportive Service payments with the Executive Director weekly for approval. Bills to be
paid weekly are recorded on the computer system and presented to the Administrator
of Business Operations for approval, then given to the Executive Director for final
approval prior to a check being issued for payment.
1B. Repay HUD $3,157 for scholarship awards that
exceeded the $500 individual limit.
The scholarship program was put on hold internally in
August 2000 because the program did not have any specific
guidelines or goals. In September 2000 the entire program
was discontinued due to the lack of program goals and
exceeding the limits of funding per each individual. The last
payment made on this program was within the program
guidelines on August 24, 2000. The Housing Commission
will repay HUD the overpayment amount of $3,157 for not
following the notice of funding program guidelines.
1C. Implement a system for measuring the effects of its
Drug Elimination Grant funded activities encompassing all
the elements required by the regulations.
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2001-CH-1003
Appendix C
The Housing Commission will develop a quantitative
performance evaluation measurement system that
encompasses all of the elements of the Drug Elimination
Grant regulation within 90 days. The new system will be
implemented within 30 days from the completion of the new
evaluation system. The Housing Commission will
incorporate these changes into all newly executed sub
grantees funded under the Drug Elimination Grant.
1D. Submit complete semi-annual reports to HUD describing
program progress and accomplishments in sufficient detail to
allow HUD to assess the Housing Commission’s
effectiveness in administering the Drug Elimination Grant
Program.
The submission of completed semi-annual reports to HUD
will be achieved through the new reporting requirement to
sub grantees and staff. A quarterly review will be instituted
for all activity under the Drug Elimination funding. The
review will be done through a monthly activity report staff
will be required to submit to the Executive Director for
review and comment. The monthly report will serve as a
guide to determine if program measures are being met.
Saginaw Housing Commission Did Not
Assure That The Tenants Organization
Properly Administered Its Drug Elimination
Grant
Finding 2
Sub-recipient agreement
Was not in effect The former agreement between the Saginaw Housing
Commission and the Saginaw Tenants Organization
was executed on February 19, 1996. I agree that
there was no formal contractual agreement in place
during the time of funding.
Tenants Organization did
Not maintain control over
2001-CH-1003 EXIT Page 44 Table of Contents
Appendix B
its grant funding I disagree with this finding. The Saginaw Tenants
Organization did have control over the funding and
was aware of disbursements from the Saginaw
Housing Commission.
Housing Commission overpaid
Tenants Organization for
Payroll taxes The Saginaw Housing Commission should have been
paying the Saginaw Tenants Organization as a sub
contractor to the Saginaw Housing Commission. The
Saginaw Tenants Organization would then be
responsible to pay all cost as any business that works
with the Saginaw Housing Commission.
Tenants Organization disbursed
Funds that should have been
returned to HUD The Housing Commission informed the Saginaw
Tenants Organization that no costs incurred after
February 1, 1999 would be reimbursable. The
Housing Commission prior to the funding restriction
distributed the $5,947 of funding the Saginaw
Tenants Organization used. The fact that the
expenditures occurred considerably after the date
they were received does not make them ineligible.
Additionally, I have not seen any documentation from
the Housing Commission requesting funding back
from the Saginaw Tenants Organization or an attempt
to put a hold/lien on the Saginaw Tenants
Organization’s bank account during this time period
by the Saginaw Housing Commission. I disagree that
this funding should be returned to HUD.
Payroll taxes and
quarterly reports not
submitted timely Paying prompt payroll taxes is an important and key
element of operating a business. The Saginaw
Tenants Organization was treated in many respects
as an independent consultant. As such, the Housing
Commission would not have been directly responsible
to ensure payment of payroll taxes.
Reported accomplishments
were not supported The establishment of specific program measures was
and is lacking in the Drug Elimination Program. The
Housing Commission should have requested detailed
information from the Saginaw Tenants Organization
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2001-CH-1003
Appendix C
to measure the performance of the programs. I agree
that the information was not sufficient. However the
Housing Commission should instruct all sub grantee
of what type of quantifiable reports are acceptable.
Consultant fees not included
In HUD approved budget
The Housing Commission is responsible for
requesting and approving additional services if those
services impact the Drug Elimination budget. The
funding to support the consultant should have been
included in the budget when submitted to HUD.
Recommendations
Office Of Inspector General
2A. Repay HUD $2,466 for excess payroll withholding taxes paid by the Housing
Commission to the Saginaw Tenants Organization.
As a sub contractor or sub grantee to the Housing Commission, the Saginaw Tenants
Organization would be responsible to make all payroll tax payments without any
direction from the Housing Commission. If an overpayment occurred it would be the
responsibility of the grantee to repay HUD the funding and seek repayment from the
sub grantee. The Housing Commissions possible error in the overpayment will be
resolved in reviewing the original program budget with the Saginaw Tenants
Organization and providing supporting documentation for the total payroll tax payments.
2B. Instruct the Tenants Organization to repay HUD $5,947 disbursed after February 1,
1999.
The funding received prior to the Housing Commission discontinuing funding were
eligible expenses as per both the Housing Commission and Saginaw Tenants
Organization. The fact that the Saginaw Tenants Organization paid its expense months
later does not invalidate the funding especially since the Housing Commission did not
seek a lien on the Saginaw Tenants Organizations bank account. I believe these funds
should not be repaid to HUD.
2C. Provide documentation to HUD supporting the fees paid to the Tenant
Organization’s consultant.
The Housing Commission will request the Saginaw
Tenants Organization to submit all supporting
documentation and deliverables the Organization
received from the consultant.
2001-CH-1003 EXIT Page 46 Table of Contents
Appendix B
Saginaw Housing Commission Did Not
Follow HUD Requirements When It Sold
Housing Commission Land
Finding 3
Disposition application submitted
to HUD after land was sold Unfortunately, this was partly true. Under a previous
Administration the Housing Commission started the
disposition process for the 2.2 acres of land without
regards to HUD regulations that are very clear in
regards to the disposition of property. A security
deposit for the property in the amount of $1,000 was
issued and held by the Housing Commission.
However, a formal closing did not take place because
of the unpaid bond on the land. A closing cannot take
place when land has not been legally cleared of all
obligations. As a result the signed warranty transfer
was not valid. This document supposedly transferred
ownership of the property. It should be noted that on
September 23, 1999 during this transaction the
Executive Director voluntarily resigned. The
application for disposition of real property was
submitted once the Board of Commissioners
appointed a new Interim Executive Director.
Environmental Assessment
prepared after the sale closed Again, I disagree that a legal closing took place on
August 13, 1999 when the property still had
obligations and debt against it. Thus, the execution of
the warranty was void. However, I do agree that the
final environmental information was not submitted
until April 2000. This was done under the Interim
Executive Director and issued to the Detroit HUD
Field Office by the current Executive Director. The
Housing Commission did comply with the
environmental requirements because the land was
never legally transferred or sold.
Land was sold at less than
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2001-CH-1003
Appendix C
fair market value In my review of the disposition application, I did not
see any documentation regarding a higher sales price
for the parcel. The former Executive Director had an
obligation to ensure that the highest amount or at
least fair market value would be received for the
property. This was a failure in the system.
Additionally, it was not revealed in my review that the
Board Member that works at Saginaw Futures, Inc.
ever stated what the former Executive Director
alleged.
Board members and the
Mayor had undisclosed
conflict of interest I disagree that two Board Members and the Mayor
had undisclosed conflicts of interest. The fact that the
Board Members and Mayor were advocating for the
selling of the property to increase economic
opportunity for the residents of the City of Saginaw
specifically, the residents within the proximity of the
new plants does not constitute a conflict of interest in
my opinion. The appearance and actual conflict of
interest are two vastly different issues. The Mayor
and Board Member that work for a General Motors
supplier did not benefit directly or indirectly from the
transaction. Whether the land was sold or not had
and has no bearing on the employment of these two
individuals. The Board Member that works at
Saginaw Futures, Inc. did not benefit directly or
indirectly from the transaction. Additionally, this
individual was never the primary staff person
responsible for the completion of the land sale at
Saginaw Futures, Inc. I believe that all three
members listed in the report are guilty of trying to
improve the economic prosperity of the northeast
section of Saginaw by advocating for jobs and
economic opportunity for the residents of the
neighborhood where the new plants were to be
constructed. This section of Saginaw has the lowest
median income and highest unemployment rate in the
City of Saginaw. I do not believe that there was a
conflict of interest on the disposition of land.
Recommendations
Office Of Inspector General
2001-CH-1003 EXIT Page 48 Table of Contents
Appendix B
3A. Take appropriate action against Board members
for not disclosing potential conflicts of interest to the full
Board and requesting any necessary waivers from
HUD.
I do not believe the Board Members had a conflict of
interest in the selling of the 2.2 acres of land in Daniels
Heights. The responsibility of following HUD
regulations and safe guarding the Housing
Commission from any irregularities was the
responsibility of the past administration. The Board
Members interest was for the community where the
new facilities are to be constructed. The area serves
Public Housing and Section 8 residents that the
Housing Commission administers. As the Executive
Director, I will assure HUD that the Housing
Commission has and will take all necessary safe
guards to ensure compliance of regulations and
address conflicts of interest.
3B. Obtain fair market value compensation for the
subject property by either (1) accepting the higher
appraised value of $13,250 or (2) publicly resoliciting
bids for the property and selling it at no less than the
highest appraised valued.
On September 7, 2000 the Office of the Assistant
Secretary for Public and Indian Housing approved the
Saginaw Housing Commission’s request for the
disposition of 2.2 acres of vacant land at Daniels
Heights. The approval was for the fair market value of
$9,000. If the Housing Commission sells any land in
the future it will be done following HUD regulations for
the highest appraised amount.
3C. Consider removing the current Board members
who were responsible for authorizing disposition of
Housing Commission land without adequate oversight
to assure that the disposition met HUD requirements.
Providing adequate oversight begins with the
administration running the day-to-day operations of the
Saginaw Housing Commission. The Executive Director
is responsible to provide direction to the Board of
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2001-CH-1003
Appendix C
Commission. The Board of Commissioners are the
policy makers and were, unfortunately put in a position
to be involved in more than policy decisions. The
disposition process should have been clearly
discussed with the full Board of Commissioners. The
failure of providing direction resulted in a process that
was nearing violation of HUD regulations. The Board of
Commissioners Interim Executive Director followed the
appropriate HUD regulations to begin to dispose of the
property. I do not believe that the Board Members
should be removed. As the Executive Director, I have
taken responsibility to inform the Board Members of
HUD regulations.
Section 8 Units Had Health and Safety
Violations
Finding 4
After reviewing this section it is clear that the Housing Commission needs to improve
the inspection process for all of its Section 8 Certificate and Voucher holders. I agree
with the report that the inspection of properties has been a weak link in the program.
Obviously, when the OIG inspector finds 278 violations and the Housing Commissions
contracted inspector identifies only 22 at the same 18 units there is a serious problem
in the program. Additionally, the photographs of the violations concrete the gross
negligence by the hired inspection contractor and lack of staff over sight in the process.
Recommendations
Office Of Inspector General
4A. Ensure that the owners correct the violations in the 18 Section 8 units where we
identified violations.
The 18 Section 8 units in this report will be re-inspected by the Housing Commissions
staff inspector to determine if the violations in the report have been repaired. If the
landlord has not made repairs, the inspector will issue a letter indicating the items that
need to be repaired and a reasonable time period to make these repairs. If all of the
repairs are not completed in the allotted time period the Housing Commission will stop
HAP payments to the landlord(s).
2001-CH-1003 EXIT Page 50 Table of Contents
Appendix B
4B. Ensure that its contract inspector properly cites all violations during his inspections.
If the inspector fails to identify all violations, the Housing Commission should take
action to obtain a new inspector.
The contract inspector services were discontinued on
June 7, 2000. The Housing Commission began
utilizing a staff member familiar with the HQS
inspection protocol to inspect the Section 8 properties.
The staff member was sent to Uniform Physical
Condition Standards training in July 2000 to learn the
new inspection standards. A temporary staff member
was also hired to assist in the inspection of Section 8
properties and public housing annual inspections. A
request for qualifications (RFQ) was issued in June
and September of this year to secure contracted
inspection services to assist staff in a limited capacity.
The Housing Commission rejected all bidders.
Currently, the Housing Commission has a full and part
time staff member responsible for Section 8
inspections. This new system has improved the quality
and control of inspections at the Section 8 properties.
As the Section 8 program expands at the Housing
Commission additional inspection staff will be added to
safe guard health and safety violations at Section 8
properties.
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2001-CH-1003
Appendix C
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2001-CH-1003 EXIT Page 52 Table of Contents
Appendix C
Distribution
Secretary
Deputy Secretary
Chief of Staff
Office of Administration
Acting Assistant Secretary for Congressional and Intergovernmental Relations
Deputy Assistant Secretary, Office of Public Affairs
Deputy Assistant Secretary for Administrative Services, Office of the Executive Secretariat
Deputy Assistant Secretary for Intergovernmental Relations
Acting Deputy Chief of Staff
Deputy Chief of Staff for Policy
Deputy Chief of Staff for Programs
Special Counsel to the Secretary
Senior Advisor to the Secretary
Special Assistant for Inter-Faith Community Outreach
Executive Officer for Administrative Operations and Management
General Counsel
Assistant Secretary for Housing/Federal Housing Commissioner
Assistant Secretary for Policy Development and Research
Assistant Secretary for Community Planning and Development
Assistant Deputy Secretary for Field Policy and Management
Office of Government National Mortgage Association
Assistant Secretary for Fair Housing and Equal Opportunity
Director, Office of Departmental Equal Employment Opportunity
Chief Procurement Officer
Assistant Secretary for Public and Indian Housing
Director, Office of Departmental Operations and Coordination
Office of the Chief Financial Officer
Chief Information Officer
Acting Director, Enforcement Center
Acting Director, Real Estate Assessment Center
Director, Office of Multifamily Assistance Restructuring
Secretary’s Representative, Midwest (2)
Senior Community Builder, Michigan State Office
Director, Office of Public Housing, Michigan State Office
Acting General Deputy Assistant Secretary, Public and Indian Housing
Deputy Assistant Secretary, Office of Administration and Budget/Chief Financial Officer
Deputy Assistant Secretary, Office of Native American Programs
Deputy Assistant Secretary for Public and Assisted Housing Delivery
Deputy Assistant Secretary, Office of Troubled Agency Recovery
Deputy Assistant Secretary for Public Housing Investments
Audit Liaison Officer, Office of Public and Indian Housing
Deputy Assistant Chief Financial Officer for Financial Management
Director, Audit Coordination Division, Departmental Audit Liaison Officer
Director, Risk Management Division
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2001-CH-1003
Appendix C
Chief Financial Officer, Audit Liaison Officer
Primary Audit Liaison Officer – Eastern Districts (Philadelphia)
Acquisitions Librarian
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, 340 Dirksen
Senate
Office Building, United States, Senate, Washington, DC 20510
The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs, 706
Hart Senate Office Building, United States, Senate, Washington, DC 20510
The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn
Building, House of Representatives, Washington, DC 20515
The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204
Rayburn Building House of Representatives, Washington DC 20515
Armando Falcon, Director, Office of Federal Housing Enterprise Oversight, 1700 G Street, NW
Room 4011, Washington, DC 20552
Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212 O’Neil House
Office Building, Washington, DC 20515
Stanley Czerwinski, Associate Director, Resources, Community and Economic Development
Division, United States General Accounting Office, 441 G Street, NW, Room 2T23, Washington
DC 20548
Steve Redburn, Chief, Housing Branch, Office of Management & Budget, 725 17th Street, NW,
Room 9226, New Executive Office Building, Washington, DC 20503
2001-CH-1003 EXIT Page 54 Table of Contents
Saginaw Housing Commission Low Income Housing Section 8 and Drug Elimination Grant Programs
Published by the Department of Housing and Urban Development, Office of Inspector General on 2001-01-04.
Below is a raw (and likely hideous) rendition of the original report. (PDF)