oversight

Youngstown Metropolitan Housing Authority Comprehensive Audit, Youngstown, OH

Published by the Department of Housing and Urban Development, Office of Inspector General on 2001-03-09.

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

           AUDIT REPORT




YOUNGSTOWN METROPOLITAN HOUSING AUTHORITY
          COMPREHENSIVE AUDIT

            YOUNGSTOWN, OHIO

                2001-CH-1004

               MARCH 9, 2001



           OFFICE OF AUDIT, MIDWEST
               CHICAGO, ILLINOIS




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                                                                        Issue Date
                                                                             March 9, 2001

                                                                       Audit Case Number
                                                                             2001-CH-1004




TO:             Thomas S. Marshall, Director of Public Housing Hub, Cleveland Area Office

                     /signed/
FROM:           Dale L. Chouteau, District Inspector General for Audit, Midwest

SUBJECT:        Youngstown Metropolitan Housing Authority
                Comprehensive Audit
                Youngstown, Ohio

We completed an audit of the Youngstown Metropolitan Housing Authority. The objectives of our
audit were to: (1) determine whether the Housing Authority had sufficient controls for safeguarding cash
and other monetary assets and inventory; (2) review for indicators of possible waste, loss, and misuse of
cash or other monetary assets and inventory; (3) establish, if appropriate, the amount of any
misappropriations, their causes, and the individuals involved; (4) determine whether the Authority
managed its Section 8 Program efficiently and effectively; and (5) assess the appropriateness of the
Authority’s procurement process. We performed the audit based on the results of an Operation Safe
Home Probe of the Authority.

The Housing Authority’s procurement process was generally performed correctly and the Authority had
sufficient controls over inventory. However, the Authority lacked sufficient controls over safeguarding
cash and other monetary assets. Specifically, the Authority: used $44,216 of Public Housing Drug
Elimination Program funds to pay the City of Youngstown for baseline police services that the City was
required to provide at no cost; was under charged $32,586 for supplemental police services by the
City; lacked documentation to support that $8,210 in police services paid were reasonable and
necessary expenses of the Authority; failed to sufficiently pursue amounts owed to it by current and
former Section 8 tenants; did not properly account for $32,300 of former Section 8 tenant accounts
receivable; and lacked an acceptable cost allocation plan to support the allocation of indirect costs
among its programs. While we found that the Authority’s controls over Section 8 tenant accounts
receivable were poor and offered the opportunity for its employees to misuse or divert funds, we found
no evidence that funds were diverted.




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Management Memorandum


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 have them contact me at (312) 353-7832 or Heath
Wolfe, Assistant District Inspector General for Audit, at (312) 353-6236 extension 2677.




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Executive Summary
We completed a review of the Youngstown Metropolitan Housing Authority. The review objectives
were to: determine whether the Housing Authority had sufficient controls for safeguarding cash and
other monetary assets and inventory; review for indicators of possible waste, loss, and misuse of cash or
other monetary assets and inventory; establish, if appropriate, the amount of any misappropriations, their
causes, and the individuals involved; determine whether the Authority managed its Section 8 Program
efficiently and effectively; and assess the appropriateness of the Authority’s procurement process. The
review resulted from an Operation Safe Home Probe of the Authority.

The Housing Authority’s procurement process was generally performed correctly and the Authority had
sufficient controls over inventory. However, the Authority lacked sufficient controls over safeguarding
cash and other monetary assets. Specifically, the Authority: used $44,216 of Public Housing Drug
Elimination Program funds to pay the City of Youngstown for baseline police services that the City was
required to provide at no cost; was under charged $32,586 for supplemental police services by the
City; lacked documentation to support that $8,210 in police services paid were reasonable and
necessary expenses of the Authority; failed to sufficiently pursue amounts owed to it by current and
former Section 8 tenants; did not properly account for $32,300 of former Section 8 tenant accounts
receivable; and lacked an acceptable cost allocation plan to support the allocation of indirect costs
among its programs. While we found that the Authority’s controls over Section 8 tenant accounts
receivable were poor and offered the opportunity for its employees to misuse or divert funds, we found
no evidence that funds were diverted.


                                        The Housing Authority: (1) used $44,216 of Public Housing
  Controls Over Police                  Drug Elimination Program funds to pay the City of Youngstown
  Services Were Weak                    for baseline police services that the City was required to
                                        provide at no cost; (2) was under charged $32,586 for
                                        supplemental police services by the City; and (3) failed to
                                        maintain documentation to support that $8,210 in police
                                        services paid were reasonable and necessary expenses of the
                                        Authority. The Authority did not have sufficient procedures and
                                        controls over the supplemental police services. As a result,
                                        HUD funds were not efficiently and effectively used.

                                        The Housing Authority did not follow its Section 8
  Tenant Accounts                       Administrative Plan or HUD’s Consolidated Annual
  Receivable Efforts Were               Contributions Contract regarding Section 8 tenant accounts
  Poor                                  receivable. Specifically, the Authority did not: sufficiently
                                        pursue amounts owed to it by current and former Section 8
                                        tenants; and properly account for $32,300 of former Section 8
                                        tenant accounts receivable. The Authority’s former top
                                        management’s failure to aggressively pursue delinquent accounts

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Executive Summary


                              and to recognize that failure to do so increased the risk of
                              collection losses.

                              The Housing Authority did not have an acceptable cost
 The Authority Lacked An      allocation plan to support the allocation of indirect costs among
 Acceptable Cost Allocation   its programs. Specifically, the Housing Authority’s cost
 Plan                         allocation plan did not address employees’ salaries. The
                              Authority also failed to properly allocate non-salary costs to its
                              Comprehensive Grant Program, Development Program, Public
                              Housing Drug Elimination Program, Major Renovation of
                              Obsolete Public Housing Program, Economic Development
                              Social Services Program, or its Service Coordinators Program.
                              Employees’ salaries were allocated to the Housing Authority’s
                              various programs based upon unsupported estimates. Housing
                              authorities must allocate indirect costs to benefiting grant
                              programs based upon specific methods, such as a time study.
                              The Housing Authority’s former Executive Director could not
                              explain the basis used for allocating the non-salary indirect
                              costs. As a result, neither HUD nor the Housing Authority had
                              assurance that costs charged to the Authority’s various
                              programs were reasonable in relation to the benefits they
                              derived from the indirect costs.

                              We recommend that HUD’s Director of the Public Housing
 Recommendations              Hub, Cleveland Area Office, assure that the Housing Authority
                              implements controls to correct the weaknesses cited in this
                              report.

                              We presented our draft findings to the Housing Authority’s
                              Executive Director and HUD’s staff during the audit. We held
                              an exit conference with the Authority on January 9, 2001. The
                              Authority agreed to implement corrective action to address the
                              findings.

                              We included excerpts of the Housing Authority’s comments
                              with each finding (see Findings 1, 2, and 3). The complete text
                              of the comments is in Appendix B with the exception of three
                              attachments that were not necessary for understanding the
                              Authority’s comments. A complete copy of the Authority’s
                              comments with the attachments was provided to HUD’s
                              Cleveland Area Office Director of the Public Housing Hub.



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Table Of Contents

Management Memorandum                                                          i



Executive Summary                                                             iii



Introduction                                                                   1



Findings

1    The Authority Did Not Have Sufficient Controls Over Its
     Supplemental Police Services                                             3


2    Section 8 Tenant Accounts Receivable Efforts Need To
     Be Improved                                                              9


3    The Authority Lacked An Acceptable Cost Allocation Plan              13



Management Controls                                                       17



Follow Up On Prior Audits                                                 19



Appendices
     A       Schedule of Questioned Costs                                21

     B       Audit Comments                                              23

     C       Distribution                                                29




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Introduction
The Youngstown Metropolitan Housing Authority was established under Section 3735.27 of the Ohio
Revised Code. The Authority contracts with HUD to provide low and moderate-income persons with
safe and sanitary housing through rent subsidies. A five member Board of Commissioners governs the
Authority. The Chairman of the Board is Robert Bush. During the audit, the Authority’s former
Executive Director Rudy Vazmina resigned effective June 1, 2000. The Authority’s current Director is
Eugenia Atkinson. The Authority's books and records are located at 131 West Boardman Street,
Youngstown, Ohio.

As of November 2000, the Housing Authority operated 10 programs: (1) a Low-Income Housing
Program consisting of 1,423 units; (2) a Section 8 Rental Assistance Program consisting of 1,258 units;
(3) a Comprehensive Grant Program; (4) a Public Housing Drug Elimination Grant Program; (5) an
Economic Development Supportive Services Grant Program; (6) a Section 8 New Construction
Program consisting of 44 units; (7) a Development Program; (8) a Major Renovation of Obsolete
Public Housing Program; (9) a Services Coordinators Program; and (10) a HOPE VI Demolition Grant
Program.


                                       The audit objectives were to: determine whether the Housing
 Audit Objectives                      Authority had sufficient controls for safeguarding cash and other
                                       monetary assets and inventory; review for indicators of possible
                                       waste, loss, and misuse of cash or other monetary assets and
                                       inventory; establish, if appropriate, the amount of any
                                       misappropriations, their causes, and the individuals involved;
                                       determine whether the Authority managed its Section 8
                                       Program efficiently and effectively; and assess the
                                       appropriateness of the Authority’s procurement process.

                                       We conducted the audit at HUD’s Cleveland Area Office and
 Audit Scope And                       the Housing Authority’s office. We performed our on-site audit
 Methodology                           work between June 1999 and December 2000.

                                       To determine whether the Housing Authority had sufficient
                                       controls over its operations, we interviewed: HUD’s staff; the
                                       Authority’s officials, staff, and tenants; and the City of
                                       Youngstown’s police officers assigned to provide supplemental
                                       police services to the Authority. We analyzed the following
                                       items: tenant files; cash disbursements and invoices; vendor files
                                       and contracts; Board meeting minutes; payroll records and
                                       personnel files; tenant accounts receivable ledgers; the cost
                                       allocation plan; supplemental police services’ activity reports;
                                       audited financial statements; and the Authority’s policies and

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Introduction


               procedures. We also reviewed: HUD’s files for the Authority;
               Section 309 of the Annual Contributions Contract between
               HUD and the Authority; Part 85 of Title 24 of the Code of
               Federal Regulations; Office of Management and Budget
               Circular A-87; the Cooperative Agreement dated July 21,
               1992, between the Authority and the City of Youngstown;
               Section 14 of the Consolidated Annual Contributions Contract
               for the Rental Certificate and Rental Voucher Programs,
               between the Authority and HUD; and HUD’s Notices of
               Funding Availability for the Public Housing Drug Elimination
               Program dated May 23, 1997 and March 31, 1998.

               The audit covered the period July 1, 1997 through June 30,
               1999. This period was adjusted as necessary. We conducted
               the audit in accordance with generally accepted government
               auditing standards.

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




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                                                                                               Finding 1


 The Authority Did Not Have Sufficient Controls
     Over Its Supplemental Police Services
The Youngstown Metropolitan Housing Authority: (1) used $44,216 of Public Housing Drug Elimination
Program funds to pay the City of Youngstown for baseline police services that the City was required to
provide at no cost; (2) was under charged $32,586 for supplemental police services by the City; and
(3) failed to maintain documentation to support that $8,210 in police services paid were reasonable and
necessary expenses of the Authority. The Housing Authority did not have sufficient procedures and
controls over the supplemental police services. As a result, HUD funds were not efficiently and
effectively used.


                                       HUD’s Notices of Funding Availability for the Public Housing
  HUD’s Requirements                   Drug Elimination Program dated May 23, 1997 and March 31,
                                       1998 required supplemental police services to be over and
                                       above the local police department’s current level of baseline
                                       services. Baseline services were defined as ordinary and
                                       routine services provided to residents as part of the overall city
                                       deployment of police services. Baseline services include
                                       patrols, police officer responses to 911 communications and
                                       other calls for service, and investigative follow-up of criminal
                                       activity. The Notices also required that a daily activity and
                                       incident complaint form be completed by each patrol. The form
                                       is necessary for the collection and analysis of criminal incidents
                                       and responses to service calls.

                                       Section 309 of the Annual Contributions Contract between
                                       HUD and the Youngstown Metropolitan Housing Authority
                                       requires the Authority to maintain complete and accurate books
                                       of account and records.

                                       24 CFR Part 85.36(i)(11) requires grantees or subgrantees to
                                       retain all required records for three years, after final payments
                                       and until all other pending matters are closed. Part 85.22(b)
                                       requires that State, local, and Indian tribal governments follow
                                       Office of Management and Budget Circular A-87, Cost
                                       Principles for State, Local, and Indian Tribal Governments. 24
                                       CFR Part 85.3 defines a local government to include any public
                                       housing agency.



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Finding 1


                             Office of Management and Budget Circular A-87, Attachment
  Office Of Management And   A, paragraph C.1.a., requires that all costs must be necessary
  Budget’s Requirements      and reasonable for proper and efficient administration of
                             Federal Awards. In addition, paragraph C.1.j. requires all
                             costs to be adequately documented. Attachment B, Section
                             23.a.(5), of the Circular says the general costs of government
                             services normally provided to the general public, such as fire
                             and police, are not allowable expenses.

                             The Cooperative Agreement dated July 21, 1992, between the
  Cooperative Agreement’s    Youngstown Metropolitan Housing Authority and the City of
  Terms                      Youngstown, required the Housing Authority’s residents to
                             receive the same services as other City residents at no
                             additional cost to the Authority or its residents.

                             Contrary to HUD’s Notice of Funding Availability, the Housing
  The Authority Improperly   Authority used Public Housing Drug Elimination Program funds
  Paid For Baseline Police   to pay the City of Youngstown for baseline police services that
  Services                   were not related to the Authority’s supplemental police
                             services. Baseline police services are services that the local
                             government must provide to the Housing Authority and its
                             residents at no cost, such as 911 emergency calls and police
                             mandated training.

                             Between January 1, 1998 and December 31, 1999, the
                             Housing Authority spent $44,216 in Public Housing Drug
                             Elimination Program funds for police officers to respond to 911
                             emergency calls and to attend two police mandated training
                             courses. The 911 emergency calls and the training courses
                             were not related to the supplemental police services provided to
                             the Authority. The Detective Sergeant-in-Charge of the
                             Housing Authority’s supplemental police services said the
                             supplemental police officers were expected to respond to 911
                             emergency calls and to attend the training courses.

                             The Housing Authority’s Quality Assurance Officer, who was
                             responsible for reviewing the supplemental police services
                             invoices, said she did not review the invoices to determine
                             whether the City invoiced the Authority for baseline services.
                             She said no one had ever questioned whether the Housing
                             Authority’s supplemental police services included baseline
                             police services.


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                                                                                      Finding 1


                             The Housing Authority was under charged for supplemental
The Authority Was Not        police services by the City of Youngstown. Between March 1,
Fully Charged For            1998 and January 31, 1999, the City of Youngstown’s Police
Supplemental Police          Department did not charge the Authority $32,586 for
Services                     supplemental police services. The services related to the fringe
                             benefit costs of the supplemental police officers. The City did
                             not accurately update its fringe benefit calculations to account
                             for an increase in the number of supplemental police officers.
                             According to an Accounting Clerk for the Housing Authority,
                             the Authority did not verify the City’s calculations of all fringe
                             benefits.

                             The Housing Authority could not support $8,210 paid to the
The Housing Authority Paid   City of Youngstown for supplemental police services. The
For Unsupported Police       Authority either did not receive or could not locate all of the
Services                     daily patrol activity reports for the period between January 1,
                             1998 and December 31, 1999. The Housing Authority and the
                             City of Youngstown’s Police Department could not provide the
                             daily patrol activity reports to support the supplemental police
                             services.

                             The Housing Authority’s Quality Assurance Officer said the
                             Authority was not aware that it did not have all of the required
                             daily activity reports because it did not use the reports to verify
                             the hours invoiced by the City. Instead, the Authority used the
                             Police Department's roll call sheets to verify the hours invoiced
                             by the City. The roll call sheets did not show the number of
                             hours the officers worked for each shift. Therefore, the
                             Housing Authority could not fully support the supplemental
                             police services paid.


Auditee Comments             Excerpts paraphrased from the Housing Authority’s comments
                             on our draft finding follow. Appendix B, pages 24 and 25,
                             contains the complete text of the comments for this finding.

                             The Housing Authority requested reimbursement of $11,630
                             ($44,216 for the baseline police services less $32,586 for the
                             police services that were under charged) for the baseline police
                             services that were improperly paid to the City of Youngstown.
                             The Authority also requested the City to provide a fringe
                             benefits calculations for each officer when it submits the monthly
                             invoice for the supplemental police services.

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Finding 1


                     Due to construction underway at the Authority’s office, access
                     to the records storage area is not permissible. The Authority
                     requested the Detective Sergeant of the supplemental police
                     officers to provide documentation to support the $8,210 in
                     unsupported police services. The Authority will submit the
                     supporting documentation to show that the services were
                     reasonable and necessary expenses of the Authority.

                     The Housing Authority established procedures and controls
                     over its supplemental police services to ensure the services meet
                     HUD’s requirements, Office of Management and Budget
                     Circular A-87, and the Authority’s Cooperative Agreement.
                     The procedures and controls include: the monthly invoices from
                     the Youngstown Police Department will contain a schedule of
                     the fringe benefits and the number of hours worked per day for
                     each officer; Officers’ time sheets will be compared to 911 call
                     sheets to ensure that baseline services are not charged to the
                     Authority; and future contracts with the Youngstown Police
                     Department or other law enforcement agencies will clearly
                     define that 911 calls and police mandated training are not
                     eligible supplemental police services expenses.

 OIG Evaluation Of   The actions taken or planned by the Housing Authority should
 Auditee Comments    improve its controls over the supplemental police services. If
                     the Authority cannot provide documentation to support that the
                     $8,210 in services were reasonable and necessary expenses of
                     the Authority, then Authority should reimburse its Public
                     Housing Drug Elimination Program from non-Federal funds.



 Recommendations     We recommend that the Director of the Public Housing Hub,
                     Cleveland Area Office, assure that the Youngstown
                     Metropolitan Housing Authority:

                     1A.     Requires the City of Youngstown to reimburse the
                             Housing Authority $11,630 ($44,216 for the baseline
                             police services less $32,586 for the police services that
                             were under charged) for the baseline police services
                             that were improperly paid. If the City does not
                             reimburse the Housing Authority, then the Authority
                             should reimburse its Public Housing Drug Elimination
                             Program $11,630 from non-Federal funds.


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                                                             Finding 1


       1B.    Provides documentation to support that the $8,210 of
              supplemental police service costs cited in this finding
              were reasonable and necessary expenses of the
              Authority. If the Housing Authority cannot provide
              supporting documentation, then the Authority should
              reimburse its Public Housing Drug Elimination Program
              $8,210 from non-Federal funds.

       1C.    Establishes procedures and controls over its
              supplemental police services to ensure the services meet
              HUD’s requirements, Office of Management and
              Budget Circular A-87, and the Housing Authority’s
              Cooperative Agreement.




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                                                                                                Finding 2


   Section 8 Tenant Accounts Receivable Efforts
              Need To Be Improved
The Youngstown Metropolitan Housing Authority did not follow its Section 8 Administrative Plan or
HUD’s Consolidated Annual Contributions Contract regarding Section 8 tenant accounts receivable.
Specifically, the Housing Authority did not: sufficiently pursue amounts owed to it by current and former
Section 8 tenants; and properly account for $32,300 of former Section 8 tenant accounts receivable.
The Housing Authority’s former top management’s failure to aggressively pursue delinquent accounts
and to recognize that failure to do so increased the risk of collection losses.


                                        The Consolidated Annual Contributions Contract for the Rental
  HUD’s Requirement                     Certificate and Rental Voucher Programs, Section 14, requires
                                        the Housing Authority to maintain complete and accurate books
                                        of account and records.

                                        The Housing Authority's Section 8 Administrative Plan effective
  Housing Authority’s                   June 1, 1998, page 37, states the Section 8 Coordinator will
  Requirements                          accept a repayment agreement from a family for a period not to
                                        exceed 12 months. The repayment agreement will require three
                                        consecutive payments of $50 or the family's participation in the
                                        Section 8 Program will be terminated. The Authority updated
                                        its Section 8 Administrative Plan on April 20, 2000. The
                                        updated Plan also required the Authority to terminate the
                                        Section 8 assistance to recipients who fail to make three
                                        consecutive payments on a repayment agreement.

                                        The responsibility for carrying out the Housing Authority’s
 Responsibilities Of                    policies and managing the Authority's day-to-day operations
 Management Staff                       rests with the Authority’s principal management staff. In
                                        particular, the management staff must maintain the Housing
                                        Authority's overall compliance with its policies and procedures
                                        and Federal, State, and local laws. The management staff is
                                        also responsible for collecting rents and enforcing lease terms.

                                        The Housing Authority did not sufficiently pursue amounts owed
  Amounts Owed By Tenants               by current and former Section 8 tenants. The Authority was
  Were Not Sufficiently                 owed $6,421 from 16 current tenants and $32,300 from 45
  Pursued                               former tenants as of December 5, 2000. The current and
                                        former tenants had outstanding accounts dating as far back as
                                        December 1993.

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Finding 2


                          We selected all 61 tenants’ (16 current and 45 former) Section
                          8 files to determine what actions the Housing Authority took to
                          collect the outstanding accounts between January 1, 2000 and
                          August 30, 2000. During this time period, the Authority did not
                          notify the 16 current tenants of their outstanding accounts during
                          the months of February and May. The Authority did send
                          notices to four tenants regarding their outstanding balances
                          during January and August 2000. During the months of March,
                          April, and June 2000, the Authority notified only one tenant of
                          the amounts he owed. The Authority notified nine current
                          tenants of the amounts they owed in July 2000. Eleven of the
                          16 tenants were under repayment agreements with the
                          Authority. However, eight of the 11 tenants failed to make their
                          monthly payments as required.

                          The Housing Authority took no action to notify the 45 former
                          Section 8 tenants regarding their accounts. The former tenants
                          vacated their units between April 30, 1996 and September 30,
                          2000. The Authority lacked policies or procedures for
                          collecting from former Section 8 tenants. After the former
                          tenants left the Section 8 Program, the Authority did not attempt
                          to collect their outstanding accounts.

                          The Housing Authority’s Director of Occupancy said the
                          Authority’s former Section 8 Director did not consider the
                          collection of outstanding Section 8 tenant accounts a high
                          priority. She said efforts to collect outstanding accounts were
                          only made when the problem was brought to the former
                          Executive Director’s attention. According to the Authority’s
                          former Executive Director, he relied on the former Section 8
                          Director to pursue the outstanding tenant accounts. As a result,
                          the Housing Authority increased the potential for loss of income.

                          The Housing Authority failed to properly include former Section
 Former Tenant Accounts   8 tenant accounts receivable on the Authority’s books and
 Were Not Accounted For   records. Housing authorities must maintain accurate books and
 Properly                 records to help prevent any diversion of funds. The Authority
                          did not include 45 former Section 8 tenant accounts totaling
                          $32,300 on its books and records. The Authority did not
                          conduct periodic reconciliations of its books and records.
                          Periodic reconciliations are necessary to ensure that subsidiary
                          ledgers agree with general ledgers.


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                                                                            Finding 2


                    Since the Authority’s books and records did not include the
                    former Section 8 tenants, payments of the amounts owed could
                    have been diverted without detection. Although there was no
                    indication that funds were diverted, the opportunity existed.
                    The Housing Authority lacked procedures and controls to
                    conduct periodic reconciliations of its books and records. The
                    Authority had not reconciled the Section 8 tenant accounts
                    receivable to the General Ledger since July 24, 1998. The
                    Housing Authority’s former Executive Director said periodic
                    reconciliations were not performed because the former Finance
                    Director failed to perform his duties.


Auditee Comments    Excerpts paraphrased from the Housing Authority’s comments
                    on our draft finding follow. Appendix B, pages 26 and 27,
                    contains the complete text of the comments for this finding.

                    The Housing Authority’s Director of Occupancy established
                    policies and procedures to ensure the collection of outstanding
                    Section 8 tenant accounts receivable. The procedures and
                    controls include establishing repayment agreements with current
                    Section 8 tenants with outstanding balances. The agreements
                    will require monthly payments toward the outstanding balances
                    as required by the Authority’s Section 8 Administrative Plan. If
                    monthly payments are not received, the Authority will send
                    reminder notices to the tenants. After three consecutive months
                    of non-payment, the tenants will be terminated from the Section
                    8 Program. The Authority will maintain documentation of all
                    written and oral communication with the tenants.

                    The Authority’s Director of Occupancy plans to establish a
                    system of controls to record, monitor, and report the collections
                    in conjunction with the Authority’s Finance Director. Where
                    possible, the Authority will pursue collection of vacated Section
                    8 tenant accounts receivable. The Finance Director plans to
                    establish policies and procedures to properly record all tenant
                    accounts and to reconcile the accounts to the Authority’s books
                    and records.

OIG Evaluation Of   The actions taken or planned by the Housing Authority should
Auditee Comments    improve its controls over Section 8 tenant accounts receivable.



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Finding 2



   Recommendations   We recommend that the Director of the Public Housing Hub,
                     Cleveland Area Office, assure that the Youngstown
                     Metropolitan Housing Authority:

                     2A.    Establishes policies, procedures, and/or controls to
                            ensure the collection of outstanding Section 8 tenant
                            accounts receivable. The procedures and controls
                            should include reviews by the Housing Authority's
                            management to determine what actions have and should
                            be taken to collect the outstanding accounts.

                     2B.    Establishes and implements policies and procedures to
                            properly record all tenant accounts. The policies and
                            procedures should include controls to assure periodic
                            reconciliations of the Housing Authority's books and
                            records.




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                                                                                             Finding 3


       The Authority Lacked An Acceptable Cost
                   Allocation Plan
The Youngstown Metropolitan Housing Authority did not have an acceptable cost allocation plan to
support the allocation of indirect costs among its programs. Specifically, the Housing Authority’s cost
allocation plan did not address employees’ salaries. The Authority also failed to properly allocate non-
salary costs to its Comprehensive Grant Program, Development Program, Public Housing Drug
Elimination Program, Major Renovation of Obsolete Public Housing Program, Economic Development
Social Services Program, or its Service Coordinators Program. Employees’ salaries were allocated to
the Housing Authority’s various programs based upon unsupported estimates. Housing authorities must
allocate indirect costs to benefiting grant programs based upon specific methods, such as a time study.
The Housing Authority’s former Executive Director could not explain the basis used for allocating the
non-salary indirect costs. As a result, neither HUD nor the Housing Authority had assurance that costs
charged to the Authority’s various programs were reasonable in relation to the benefits they derived
from the indirect costs.


                                       24 CFR Part 85.22(b) requires that State, local, and Indian
  Federal Requirements                 tribal governments follow Office of Management and Budget
                                       Circular A-87, Cost Principles for State, Local, and Indian
                                       Tribal Governments. 24 CFR Part 85.3 defines a local
                                       government to include any public housing agency.

                                       Office of Management and Budget Circular A-87, Attachment
                                       A, states in part that State, local, and Federally-recognized
                                       Indian tribal governments shall establish principles to provide
                                       that Federal awards bear their fair share of costs. Attachment
                                       C of the Circular states in part that governments need a process
                                       whereby costs can be assigned to benefited activities on a
                                       reasonable and consistent basis. The cost allocation plan
                                       provides that process. All cost and other data used to
                                       distribute the costs included in the plan should be supported by
                                       formal accounting and other records that support the propriety
                                       of the costs assigned to Federal awards.

                                       The Housing Authority did not have an acceptable cost
  The Authority Lacked An              allocation plan. The plan did not address employees’ salaries.
  Acceptable Plan                      The Authority allocated employees’ salaries and benefits for
                                       Fiscal Year 2000 based upon estimates. The Authority did not
                                       have documentation to support the estimates. Allocating costs
                                       to Federal programs based upon unsupported estimates is not

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Finding 3


                             an acceptable method. Housing authorities must document an
                             acceptable cost allocation plan.

                             We selected 13 of the Housing Authority’s employees whose
                             salaries were charged to the Authority’s various programs to
                             determine the time they spent related to the programs. Twelve
                             of the 13 employees said they spent either more or less time
                             than the percentage the Housing Authority charged to its various
                             programs; one indicated that the percentage of her salary was
                             properly allocated.

                             For example, in Fiscal Year 2000, the Housing Authority
                             allocated the salaries of its three General Accounting Clerks in
                             the same manner. Sixty-one percent was allocated to the
                             Public Housing Program, 25 percent to the Comprehensive
                             Grant Program, 10 percent to the Section 8 Program, three
                             percent to the Major Renovation of Obsolete Public Housing
                             Program, and one percent to the Development Program.
                             However, the three Clerks performed different tasks for the
                             Authority’s various programs. The following table shows the
                             three Clerks’ estimates of time spent on each Program.

                    Employee                     Estimated Time Spent On Programs
               Accounting Clerk A     •       60 Percent-Comprehensive Grant
                                      •       15 Percent-Public Housing Drug Elimination
                                      •       10 Percent-Public Housing
                                      •       10 Percent-Major Renovation of Obsolete Public
                                              Housing
                                      •       5 Percent-Development and Economic
                                              Development Social Services
               Accounting Clerk B     •       70 Percent-Public Housing
                                      •       25 Percent-Section 8
                                      •       5 Percent-Section 8 New Construction,
                                              Comprehensive Grant, Development, Public
                                              Housing Drug Elimination, and Economic
                                              Development
               Accounting Clerk C     •       60 Percent-Public Housing
                                      •       20 Percent-Comprehensive Grant
                                      •       10 Percent-Section 8
                                      •       10 Percent-Section 8 New Construction, Major
                                              Renovation of Obsolete Public Housing, Public
                                              Housing Drug Elimination, and Economic
                                              Development

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                                                                          Finding 3


                   The Housing Authority did not properly allocate non-salary
                   costs such as electricity, water, property hazard insurance, and
                   fidelity bond insurance for its central office to all of the
                   benefiting programs. The Authority allocated the non-salary
                   costs as follows: 50 percent to the Public Housing Program; 40
                   percent to the Section 8 Program; and 10 percent to its Section
                   8 New Construction Program. The Comprehensive Grant,
                   Development, Public Housing Drug Elimination, Major
                   Renovation of Obsolete Public Housing, Economic
                   Development Social Services, and the Authority’s Service
                   Coordinators Programs occupy part of the office space and use
                   the same staff at the Housing Authority’s central office.
                   Therefore, the Public Housing Program, Section 8 Program,
                   and the Section 8 New Construction Program incurred costs
                   that were not related to their Program.

                   The Housing Authority’s former Executive Director could not
                   explain the basis used for allocating the non-salary indirect
                   costs. The Authority lacked documentation to support the
                   percentages used to allocate the indirect costs. During the last
                   three years, the Authority has had two Finance Directors and at
                   least three Interim Finance Directors. The Authority’s former
                   Finance Directors did not ensure that the Housing Authority had
                   an adequate plan. The Housing Authority hired a new Finance
                   Director in May 2000.

                   As a result, the Housing Authority and HUD lacked assurance
                   that costs charged to the Authority’s various programs were
                   reasonable in relation to the benefits they derived from the
                   indirect costs.


Auditee Comments   Excerpts paraphrased from the Housing Authority’s comments
                   on our draft finding follow. Appendix B, page 23, contains the
                   complete text of the comments for this finding.

                   The Housing Authority completed a cost allocation study to
                   allocate employees’ salaries to the benefiting programs in
                   September 2000. In the future, the Authority will conduct
                   studies on a periodic basis to ensure that costs are charged to
                   the appropriate programs. The Authority’s Finance Director
                   will be responsible for maintaining the cost allocation plan
                   according to Office of Management and Budget Circular A-87.

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Finding 3


                       Due to construction work underway at the Housing Authority’s
                       office, the Authority has not established a cost allocation plan to
                       allocate non-salary indirect costs to its various programs. The
                       Authority will establish a plan to allocate the costs once the
                       construction work is completed,.

   OIG Evaluation Of   The Housing Authority did not provide the September 2000
   Auditee Comments    cost allocation plan with its response to this draft finding.
                       Therefore, we were unable to determine whether the plan met
                       the requirements of Office of Management and Budget Circular
                       A-87. The Authority should ensure that the cost allocation plan
                       meets the requirements of Circular A-87. In addition, the
                       Authority needs to establish a cost allocation plan to allocate
                       non-salary costs as soon as possible. Once this is completed,
                       the Authority should reallocate the indirect costs charged to the
                       appropriate programs for Fiscal Year 2000.


  Recommendations      We recommend that the Director of the Public Housing Hub,
                       Cleveland Area Office, assure that the Youngstown
                       Metropolitan Housing Authority:

                       3A.     Develops a cost allocation plan in accordance with
                               Office of Management and Budget Circular A-87.

                       3B.     Reallocates the indirect costs charged to the
                               appropriate programs for Fiscal Year 2000, once the
                               cost allocation plan is developed.

                       3C.     Establishes procedures and controls to update its cost
                               allocation plan as necessary.




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Management Controls
In planning and performing our audit, we considered the management controls of the Youngstown
Metropolitan Housing Authority in order to determine our auditing procedures, not to provide assurance
on the controls. Management controls include the plan of organization, methods, and procedures
adopted by management to ensure that its goals are met. Management controls include the processes
for planning, organizing, directing, and controlling program operations. They include the systems for
measuring, reporting, and monitoring program performance.



                                       We determined the following management controls were
  Relevant Management
                                       relevant to our audit objectives:
  Controls

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

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

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

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

                                       We assessed all of the relevant controls identified above.

                                       It is a significant weakness if management controls do not
                                       provide reasonable assurance that the process for planning,
                                       organizing, directing, and controlling program operations will
                                       meet an organization’s objectives.

                                       Based on our review, we believe the following items are
  Significant Weaknesses
                                       significant weaknesses:



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Management Controls


                      ·   Program Operations

                          The Housing Authority was not operated according to
                          program requirements. Specifically, the Authority: used
                          $44,216 of Public Housing Drug Elimination Program funds
                          to pay the City of Youngstown for baseline police services
                          that the City was required to provide at no cost; was under
                          charged $32,586 for supplemental police services by the
                          City; failed to maintain documentation to support that
                          $8,210 in police services paid were reasonable and
                          necessary expenses of the Authority; sufficiently pursue
                          amounts owed to it by current and former Section 8
                          tenants; properly account for $32,300 of former Section 8
                          tenant accounts receivable; and did not have an acceptable
                          cost allocation plan to support the allocation of indirect
                          costs among its programs (see Findings 1, 2, and 3).

                      ·   Validity and Reliability of Data

                          The Housing Authority did not properly account for former
                          Section 8 tenant accounts receivable (see Finding 2).

                      ·   Compliance with Laws and Regulations

                          The Housing Authority did not follow HUD’s requirements
                          and Office of Management and Budget’s Circular A-87
                          regarding supplemental police services and the cost
                          allocation plan (see Findings 1 and 3).

                      ·   Safeguarding Resources

                          The Housing Authority improperly used $52,426 of Public
                          Housing Drug Elimination Program funds for ineligible and
                          unsupported supplemental police services (see Finding 1).




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Follow Up On Prior Audits
The Office of Inspector General issued an audit report on the Youngstown Metropolitan Housing
Authority on February 26, 1993 pertaining to the operations of its Section 8 Existing and Housing
Voucher Programs (Audit Case Number 93-CH-203-1013). The report contained seven findings.
The recommendations for the seven findings were closed. One finding is repeated in this report.


   Report Number 93-CH-203-1013                                 This Report

The Housing Authority Did Not Correctly                The Authority Lacked An Acceptable
Charge Indirect Costs To Its Programs                  Cost Allocation Plan (Finding 3).
(Finding 5).


The latest single audit for the Housing Authority covered the fiscal year ended June 30, 1999. The
report contained no findings.




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                                                                                            Appendix A

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


                       1A                    $ 11,630
                       1B                                           $8,210
                      Total                  $ 11,630              $ 8,210


1/          Ineligible costs are costs charged to a HUD-financed or insured program or activity that the
            auditor believes are not allowable by law, contract, or Federal, State, or local policies or
            regulations.

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




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                                                                                                Appendix B

Auditee Comments
December 5, 2000

                                                           VIA FACSIMILE
                                                           ORIGINAL FIRST CLASS MAIL
U.S. Department of Housing
 And Urban Development
Office of Inspector General for Audit, Midwest
Ralph H. Metcalfe Federal Building
77 West Jackson Blvd., Room 2646
Chicago, Illinois 60604-3507

Attention: Mr. Heath Wolfe
           Assistant District Inspector General
           For Audit, Midwest

        RE: Draft Audit Findings

Dear Mr. Wolfe:

        I am writing this letter in response to the areas of concern identified in your draft audit findings
concerning Youngstown Metropolitan Housing Authority’s cost allocation plan and insufficient controls
over supplemental police services.

AREA OF CONCERN:                    Authority Lacked An Acceptable Cost Allocation
                                    Plan

RESPONSE: In addition to the cost allocation update initiated in February, 2000 as
discussed in Mr. Rudy Vazmina’s correspondence of February 25, 2000, the Authority
will conduct cost allocation studies on a periodic basis to ensure that indirect costs are
charged to the appropriate programs. The most recent study was completed in
September, 2000; and I have attached a copy of this analysis for your records.

Moreover, Mr. Gary Cameron was hired as YMHA Finance Director on May 15, 2000.
Mr. Cameron will be responsible for maintaining a cost allocation process in
accordance with Office of Management and Budget Circular A-87.

The Authority has not established an indirect cost allocation plan for insurance,
maintenance, repairs, utilities, etc. based upon square foot rental space. Currently,
YMHA is in the process of completely renovating the Amedia Plaza building which
houses residents and our administrative offices. Due to the time involvement, and the
fact that administrative office locations will be changed during the next few months, it

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Appendix B


U.S. Department of Housing                                       Page Two
 And Urban Development
Mr. Heath Wolfe
December 5, 2000


would not be cost efficient to conduct such a study at this time. We will, however,
provide that information upon completion of building renovation.

AREA OF CONCERN:             The Authority Improperly Paid For Baseline Police Services

Between January 1, 1998 and December 31, 1999, the Housing Authority spent $44,216 in Public
Housing Drug Elimination Program funds for police officers to respond to 911 emergency calls and to
attend two police mandated training courses. The 911 emergency calls and the training courses were
not related to the supplemental police services provided to the Authority.

RESPONSE: The Youngstown Metropolitan Housing Authority (Authority) is seeking reimbursement
from the City of Youngstown Police Department (YPD) in the amount of $11,630($44,216 for the
baseline police services less $32,586 for the police services that were under charged) for the baseline
police services that were improperly paid. Attachment 1 is a copy of the letter sent to YPD in regards
to this matter.

AREA OF CONCERN: The Authority Was Not Fully Charged For Supplemental
                  Police Services

The Housing Authority was under charged for supplemental police services by the City of Youngstown.
Between March 1, 1998 and January 31, 1999, the City of Youngstown Police Department did not
charge the Authority $32,586 for supplemental police services. The services related to the fringe benefit
costs of the supplemental police officers. The City did not update its fringe benefit calculations to
account for an increase in the number of supplemental police officers.

RESPONSE: In order to prevent the above from reoccurring, Authority has requested that updated
fringe benefit calculations for each officer are submitted with each monthly invoice. Attachment 2 is a
sample of what is submitted.


AREA OF CONCERN: The Housing Authority Paid For Unsupported Police Services

The Housing Authority could not support $8,206 paid to the City of Youngstown for supplemental
police services. The Authority either did not receive or could not locate all of the daily patrol activity
reports for the period between January 1, 1998 and December 31, 1999. The Housing Authority and
the City of Youngstown Police Department could not provide the daily patrol activity reports to support
the

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U.S. Department of Housing                                      Page Three
 And Urban Development
Mr. Heath Wolfe
December 5, 2000


supplemental police services cited in this finding was reasonable and necessary expenses of the
Authority.

RESPONSE: Due to the construction underway at Amedia Plaza, access to our records storage area
is not possible at this time. Authority has asked the Detective Sergeant of the YMHA Detail to provide
a copy of these reports to support the above supplemental police services provided by the YMHA
Detail. Authority will forward the back-up material to show that the services cited were reasonable and
necessary expenses of the Authority.

Authority has established the following procedures and controls over its supplemental police services to
ensure the services meet HUD’s requirements, Office of Management and Budget Circular A-87 and
the Housing Authority’s Cooperative Agreement:

       1.     Monthly invoices from the YPD includes a schedule of current fringe benefits for each
              officer and a breakdown of the number of hours worked daily by each officer. The number
              of hours charged to YMHA and to YPD and the number of training hours and the type of
              training will also be defined.
       2.     Time sheets will be compared to 911 call sheets to assure 911 baseline calls are not
              charged to YMHA.
       3.     Contracts with YPD and any other law enforcement agency will include language that
              clearly defines 911 calls and police mandated training as ineligible expenses.

       If you have any questions or need any further information, please contact me.

Sincerely,

/signed/

Eugenia C. Atkinson
Executive Director

/mlg

Enclosures




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Appendix B



January 4, 2001




U.S. Department of Housing
 And Urban Development
Office of Inspector General for Audit, Midwest
Ralph H. Metcalfe Federal Building
77 West Jackson Boulevard, Suite 2646
Chicago, Illinois 60604-3507

Attention: Mr. Heath Wolfe
           Assistant District Inspector General
           For Audit, Midwest

        RE: Draft Audit Findings

Dear Mr. Wolfe:

        This letter is in response to the areas of concern identified in your draft audit findings concerning
Youngstown Metropolitan Housing Authority’s Section 8 Program. The draft finding indicates YMHA
did not sufficiently pursue amounts owed by current and former Section 8 tenants and did not follow its
Section 8 Administrative Plan or HUD’s Consolidated Annual Contributions Contract relative to
Section 8 tenant accounts receivable.

RESPONSE: The Director of Occupancy has established new policies and procedures to ensure the
collection of outstanding Section 8 tenant accounts receivable and will establish a system of controls to
record, monitor, and report such collections in conjunction with YMHA’s Finance Director.

The new process includes establishment of repayment agreements with current Section 8 residents who
have outstanding balances. These agreements require monthly payments towards delinquent balances in
accordance with the Section 8 Administrative Plan. If the monthly payment is not received, a reminder
notice is forwarded to the resident. After three consecutive months of non-payment, individual(s) will
be terminated from the Section 8 Program per agreement. Documentation of all written and oral
communication with residents is maintained in individual case records.




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U.S. Department of Housing                                                         Page Two
 And Urban Development
Mr. Heath Wolfe
January 4, 2001


Where possible, YMHA will also pursue collections of tenant accounts receivable from former Section
8 residents. While future Section 8 applicants with tenant account balances will be required to pay such
balances in full prior to receiving housing assistance through the Section 8 Program. Moreover, the
Authority will enforce the policies outlined in the Section 8 Administrative Plan relative to increases in
income of Section 8 Program participants.

Finally, the Finance Director will establish policies and procedures to properly record all tenant
accounts including a procedure for periodic reconciliation of such accounts with YMHA books and
records in accordance with GAAP procedures.

           If you have any questions or need any further information, please contact me.

Sincerely,

/signed/

Eugenia C. Atkinson
Executive Director

/mlg




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                                                                                         Appendix C

Distribution
Acting Secretary's Representative, Midwest (2)
Senior Community Builder/State Coordinator, Ohio State Office
Senior Community Builder/Coordinator, Cleveland Area Office
Director of Public Housing Hub, Cleveland Area Office (2)
Secretary, S (Room 10000)
Chief of Staff, S (Room 10000)
Acting Assistant Secretary for Administration, A (Room 10110)
Acting Deputy Assistant Secretary for Administrative Services, Office of the Executive
        Secretariat, AX (Room 10139)
Acting Assistant Secretary for Congressional and Intergovernmental Relations, J (Room
        10120)
Acting Deputy Assistant Secretary for Intergovernmental Relations, JI (Room 10234)
Director of Departmental Equal Employment Opportunity, U (Room 2112)
Senior Advisor to the Secretary, Office of Public Affairs, W (Room 10132)
Acting Special Counsel to the Secretary, S (Room 10226)
Deputy Chief of Staff, S (Room 10226)
Deputy Chief of Staff for Policy and Program, S (Room 10226)
Deputy Chief of Staff for Intergovernmental Affairs, S (Room 10226)
Deputy Assistant Secretary for Public Affairs, W (Room 10222)
Special Assistant for Inter-Faith Community Outreach, S (Room 10222)
Executive Officer for Administrative Operations and Management, S (Room 10220)
General Counsel, C (Room 10214)
Deputy General Counsel for Housing, Finance, and Operations, CA (Room 10240)
Assistant General Counsel, Midwest
Acting Assistant Secretary for Housing-Federal Housing Commissioner, H (Room 9100)
Assistant Secretary for Policy Development and Research, R (Room 8100)
Acting Assistant Secretary for Community Planning and Development, D (Room 7100)
Executive Vice President of Government National Mortgage Association, T (Room 6100)
Assistant Secretary for Fair Housing and Equal Opportunity, E (Room 5100)
Chief Procurement Officer, N (Room 5184)
Assistant Secretary for Public and Indian Housing, P (Room 4100)
Acting General Deputy Assistant Secretary for Public and Indian Housing, P (Room 4100)
Deputy Assistant CFO for Financial Management, FM (Room 2206)
Deputy Assistant Secretary for Public and Assisted Housing Delivery, PH (Room 4202)
Deputy Assistant Secretary for Administration and Budget/CFO, PC (Room 4234)
Audit Liaison Officer for Public and Indian Housing, PF (Room 5156)
Chief Information Officer, Q (Room 8206)
Director of Departmental Operations and Coordination, I (Room 2124)
Acting Chief Financial Officer, F (Room 2202)
Deputy Chief Financial Officer, F (Room 2202)
Director of Audit Coordination/Departmental Audit Liaison Officer, FMA (Room 2206)

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Director of Risk Management, FMR (Room 2214)
CFO Audit Liaison Officer, FMA (Room 2206)
Audit Liaison Officer, 3AFI (2)
Acting Director of Enforcement Center, V (200 Portals Building)
Acting Director of Real Estate Assessment Center, X (1280 Maryland Avenue, SW,
        Suite 800)
Director of Multifamily Assistance Restructuring, Y (4000 Portals Building)
Assistant Deputy Secretary for Field Policy and Management, SDF (Room 7108)
Acquisitions Librarian, Library, AS (Room 8141)
Deputy Staff Director, Counsel, Subcommittee of Criminal Justice, Drug Policy & Human
        Resources, B 373 Rayburn House Office Building, Washington DC 20515
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, 340
        Dirksen Senate Office Building, United States Senate, Washington DC 20510
The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs,
        706 Hart Senate Office Building, United States Senate, Washington DC 20510
Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn
        Building, United States House of Representatives, Washington DC 20515
Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204 Rayburn
        Building, United States House of Representatives, Washington DC 20515
Ms. Cindy Sprunger, Subcommittee on Oversight and Investigations, Room 212, O'Neil
        House Office Building, Washington DC 20515
Associated Director of Resources, Community, and Economic Development Division,
    United States General Accounting Office, 441 G Street N.W., Room 2T23, Washington
    DC 20548 (Attention: Stanley Czerwinski)
Steve Redburn, Chief of Housing Branch, Office of Management and Budget, 725 17th
    Street, N.W., Room 9226, New Executive Office Building, Washington DC 20503
Executive Director, Youngstown Metropolitan Housing Authority (2)
Chairman of the Board of Commissioners, Youngstown Metropolitan Housing Authority




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