Issue Date
September 21, 2001
Audit Case Number
2001-FW-1006
TO: Katie Worsham
Director
Office of Community Planning and Development, 6AD
/SIGNED/
FROM: D. Michael Beard
District Inspector General for Audit, 6AGA
SUBJECT: Dallas Homeless Consortium
Continuum of Care
Dallas, Texas
We audited the Dallas Continuum of Care 1996 and 1997 grants as part of a nationwide review
of HUD’s Continuum of Care Program. Our attached audit report contains one finding.
Within 60 days please give us, for each recommendation made in this audit report, a status report
on: (1) corrective action taken; (2) proposed corrective action and date to be completed; or (3)
why action is considered unnecessary. Also, please furnish us copies of any correspondence or
directive issued because of this audit.
If you have any questions, please call William Nixon, Assistant District Inspector General for
Audit, at (817) 978-9309.
Management Memorandum
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2001-FW-1006 Page ii
Executive Summary
As a part of a nationwide review of HUD’s Continuum of Care Program, we audited the
Dallas Homeless Consortium. Our objectives were to determine whether the Consortium:
(1) fairly represented the needs of the community; (2) achieved broad participation; (3)
held members accountable for their performance; and (4) tracked the progress of
programs and participants.
The Continuum of Care Our audit concluded the Consortium has a broad-based
applications filed by the membership that provided fair representation of the
Homeless Consortium community. However, the Continuum of Care applications
contain inaccurate filed by the Homeless Consortium contain inaccurate
information and overstate information and overstate its achievements. The peer
its achievements. review process, used to determine the priority order of the
projects contained in the consolidated application, was
ineffective and may have allowed unsuccessful programs to
receive higher priority than was appropriate. In addition,
the Consortium had no means of tracking or monitoring its
participants or programs. We also have concerns that in its
role as lead agency of the Consortium, the City of Dallas
did not provide the organization with the leadership and
guidance necessary for the Consortium to become
successful.
We recommend HUD: (1) review the existing Continuum
Recommendations. of Care strategy of the Consortium to ensure that the
strategy accurately represents the efforts and plans of the
Consortium; (2) work with the Consortium to strengthen its
peer review process; (3) require the Consortium to
implement a tracking system; (4) continue to provide
technical assistance to the Consortium as it works through
the process of choosing a lead agency; and (5) assist the
Consortium in formalizing operational requirements for the
Consortium, the lead agency, and the Consortium members.
Page iii 2001-FW-1006
Executive Summary
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2001-FW-1006 Page iv
Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 The Consortium Misled HUD and Did Not Effectively 9
Evaluate or Provide Meaningful Feedback on Grantee
Performance
Management Controls 17
Appendices
A Auditee Comments 19
B Distribution 23
Page v 2001-FW-1006
Table of Contents
Abbreviations
HUD U. S. Department of Housing and Urban Development
NOFA Notice of Funding Availability
OIG Office of Inspector General
SRO Single Room Occupancy Dwellings Program
2001-FW-1006 Page vi
Introduction
HUD developed the Continuum of Care concept to address
Background
the needs of the homeless and was intended to provide for a
coordinated, long-term approach for meeting those needs.
HUD began implementing the Continuum of Care concept
through a Notice of Funding Availability (NOFA) in 1994.
The purpose of the NOFA was to fund projects and
activities that created locally developed Continuum of Care
systems to assist homeless persons. The Continuum of
Care system consists of four basic components:
· Outreach and assessment.
· Emergency shelter with appropriate supportive services.
· Transitional housing with appropriate supportive
services.
· Permanent housing or permanent supportive housing.
While not all homeless individuals will need to access all
four of these components, coordination of all four
components is necessary for them to be successful.
There are three competitively funded programs included
within the Continuum of Care:
· Supportive Housing Program
· Shelter Plus Care Program
· Section 8 Moderate Rehabilitation for Single Room
Occupancy Dwellings (SRO) Program
The Supportive Housing Program promotes the
development of supportive housing and supportive services
to assist homeless persons to transition from homelessness
and live as independently as possible.1 The Shelter Plus
Care Program provides rental assistance for hard-to-serve
homeless persons with disabilities in connection with
supportive services funded from sources outside the
program.2 Section 8 Moderate Rehabilitation for SRO
Program provides rental assistance for homeless individuals
in rehabilitated SRO housing.3
1
Subtitle C of Title IV of the Stewart B. McKinney Homeless Assistance Act.
2
Subtitle F of Title IV of the Stewart B. McKinney Homeless Assistance Act.
3
Subpart V of Subtitle F of Title IV of the Stewart B. McKinney Homeless Assistance Act.
Page 1 2001-FW-1006
Introduction
HUD designed the Continuum of Care programs to allow
communities the flexibility to determine what worked best
for them. In other words, it is up to the community to
determine what types of assistance it needs and what
priorities to assign to the needs. In order to give
communities this flexibility, HUD issued no regulations
governing the operation or organization of the individual
Continuum of Care organizations.4
Applications for Continuum of Care grants may be
submitted using one of three options:5
· Consolidated Application: a single application
encompassing a Continuum of Care strategy and
containing all the projects within that strategy for which
funding is being requested. Individual projects and
operators are contained within the one consolidated
application. Grant funding may go to one entity, which
then administers all funded projects submitted in the
application, or grant funding may go to all or any of the
projects individually. Communities are encouraged
however not required to submit consolidated
applications. A consolidated application is an
application developed from a single Continuum of Care
strategy for a jurisdiction (or a consortium of
jurisdictions) and contains funding requests for all of
the projects within that strategy.
· Associated Application: applicants plan and organize
a single Continuum of Care strategy which is adopted
by project sponsors or operators who choose to submit
separate applications for projects while including the
identical Continuum of Care strategy. In this case,
project funding would go to each successful applicant
individually and each would be responsible to HUD for
administering its separate grant.
· Solo Application: an applicant applies for a project
exclusive of any Continuum of Care strategy.
HUD considered consolidated and associated applications
equally competitive. However, solo applications, not part
4
1997 Continuum of Care Application.
5
1997 NOFA.
2001-FW-1006 Page 2
Introduction
of a Continuum of Care strategy, received few, if any,
points under the Continuum of Care rating criteria.
In general, applications contain two components.6 The first
component is the process and outcome of the community
based homeless plan – the Continuum of Care. It contains
a description of the community’s Continuum of Care
strategy, the process used to create that strategy and a
listing of the projects included in the application, in priority
order.7 This priority order will mean that if funds are only
available to finance eight of ten proposed projects, then
funding will be awarded to the first eight projects listed.
HUD believes that priority decisions are best made through
a locally-driven process and are key to the ultimate goal of
reducing homelessness in America. In addition, a
community’s Continuum of Care strategy should reflect
maximum participation by a range of participants.8 It
should also describe a community’s efforts to create,
maintain, and build upon a community-wide inventory of
housing and services for homeless families and individuals.
Instructions direct applicants to pay special attention to this
component since HUD places a high priority on
coordination among a spectrum of homeless assistance
providers.
The second component of the application contains the
exhibits for the specific program funds contained in the
application. These exhibits describe the individual projects
contained in the application. They contain details regarding
the population to be served, activity for which assistance is
requested, proposed participants and their needs, specific
costs associated with the project, and supportive services
proposed to help participants achieve permanent housing
and self-sufficiency.
HUD reviewed and rated all applications using the same
process. It conducted two types of reviews. HUD first
conducted a threshold review of each proposed project for
the specific criteria identified in the Notice of Funding
Availability (NOFA). HUD eliminated those projects not
meeting NOFA requirements from the competition. In the
6
1997 Continuum of Care Application.
7
The priority of projects contained in the application is determined by the local Continuum of Care organization.
8
Examples: non-profit providers of housing and services, homeless and formerly homeless persons, state and local
governments and agencies, the private sector, housing developers, foundations, and other community organizations.
Page 3 2001-FW-1006
Introduction
second review, HUD assigned up to 40 points for the
community’s fundamental need to provide housing and
services for homeless persons and up to 60 points for the
community’s Continuum of Care strategy.9
The Homeless Consortium of Dallas was organized in
Homeless Consortium of 1995. However, prior to 1997 the Consortium only met to
Dallas. discuss grant applications. According to Consortium
members, in 1997 they sought to place more emphasis on
the homeless and less on discussing funding issues. They
elected officers, established committees, broadened their
base, hired consultants and formed focus groups.
The Consortium is a combination of different types of
organizations and individuals. It consists of public entities,
service providers, private not-for-profit organizations,
business groups, and formerly homeless individuals. The
Consortium’s application contained components for
emergency shelter, transitional and permanent housing, and
service resources to address the needs of the homeless.
The City of Dallas took a lead role in the Continuum of
Care process. The City prepared and submitted the
Consolidated Application for the Consortium. This
included preparing Exhibit 1, which included the
Continuum of Care narrative. The City also paid for and
gathered the information necessary to determine “gaps” in
homeless services.10 Further, the City provided a staff
member who facilitated the ongoing activities of the
consortium and provided funding for mailings, consultants,
and other administrative matters.
The Consortium utilized a peer review process in order to
evaluate the individual Consortium members. According to
a Consortium official, any organization that applied for
Continuum of Care grant funds11 underwent a peer review.
The peer review results influenced the priority given to the
projects in the application.12 The peer review team13 relied
upon the Annual Progress Reports to determine if the
member met their goals. They also discussed with HUD
9
1997 Continuum of Care Application.
10
A “Gap Analysis” compares the existing services with the demands for those services. The difference between the existing
services and the demand for the services is considered a gap.
11
Including renewal grants.
12
1999 was the first time that the peer reviews were used in any way to determine funding priority.
13
Volunteers from the Consortium comprised the peer review team.
2001-FW-1006 Page 4
Introduction
whether the member spent their grant funds timely.
However, in reviewing the Annual Progress Report, the
review team did not look at any supporting documentation.
Our audit objectives were to determine if the Consortium:
Audit Objectives, Scope,
(1) fairly represented the needs of the community; (2)
and Methodology
achieved broad participation; (3) held members accountable
for their performance; and (4) tracked the progress of
programs and participants. We audited a judgmental
sample of seven grants awarded to members of the
Consortium during 1996 and 1997 and utilized the results
in our evaluation of the Consortium. The tables below
show the grants awarded to the Consortium members
during 1996 and 1997.14
1996 GRANTS/DALLAS HOMELESS CONSORTIUM
City of Dallas15 Shelter Plus Care Grant $1,488,600
Dallas Jewish Coalition16 Supportive Housing Grant 555,660
Housing Crisis Center17 Supportive Housing Grant 533,130
Promise House Inc. Supportive Housing Grant 777,281
PWA Coalition of Dallas Supportive Housing Grant 1,970,320
TOTAL $5,324,991
1997 GRANTS/DALLAS HOMELESS CONSORTIUM
City of Dallas18 Supportive Housing Grant $ 749,670
DCCCD Supportive Housing Grant 379,733
Family Gateway Supportive Housing Grant 337,364
Family Gateway Supportive Housing Grant 98,116
GDCADA19 Supportive Housing Grant 400,181
Housing Crisis Center20 Supportive Housing Grant 211,358
Housing Crisis Center21 Supportive Housing Grant 546,361
Legal Services of North Supportive Housing Grant 135,000
Texas
LifeNet Supportive Housing Grant 870,178
Rainbow Days Supportive Housing Grant 558,257
TOTAL $4,286,218
Our objectives in auditing the individuals grants were to
determine if: (1) the individual grants were implemented in
14
Shaded grants indicate those included in the sample of audits.
15
Audit Report number 01-FW-251-1002.
16
Audit Memorandum number 00-FW-251-1801.
17
Audit Memorandum number 00-FW-251-1804.
18
Audit Report number 01-FW-251-1002.
19
Audit Memorandum number 2001-FW-1802.
20
Audit Memorandum number 00-FW-251-1804.
21
Ibid.
Page 5 2001-FW-1006
Introduction
accordance with federal regulations and grant agreements;
(2) funds were expended for eligible activities under federal
regulations and applicable costs principles; (3) accurate and
adequate evidence of measurable results was maintained;
(4) programs were sustainable; and (5) grant funds were
expended timely. The findings of those audits are
summarized below.
Greater Dallas Council on Alcohol and Drug Abuse
Overall, the Council’s activities were consistent with its
application. However, the Council:
· Included $28,892 in ineligible and unsupported salary
and benefit costs in grant drawdowns;
· Was behind projected spending by $166,531; and
· Did not achieve its goals, which we determined was due
to the lack of cooperation of the Consortium.
City of Dallas
Overall, the City did not implement its grants in
compliance with grant agreements and federal regulations.
Specifically, the City:
· Failed to provide $250,980 in supportive services
required by its Shelter Plus Care grant or adequately
document the services it did provide;
· Was behind projected spending for its Shelter Plus Care
grant by $259,295, and $39,572 for its Supportive
Housing grant;
· Submitted inaccurate and inconsistent Annual Progress
Reports;
· Included $53,977 in ineligible and $2,261 in
unsupported costs in grant drawdowns;
· Did not monitor the participants and their supportive
service needs sufficiently; and
· Did not perform yearly Housing Quality Standards
inspections for apartments inhabited 1 year or more.
2001-FW-1006 Page 6
Introduction
Housing Crisis Center
Overall, the Center’s activities were consistent with its
application. However the Center:
· Included $48,720 in ineligible costs in grant
drawdowns;
· Submitted inaccurate Annual Progress Reports;
· Was behind projected spending; and
· Overdrew its grants by $6,995.
Dallas Jewish Coalition
The Coalition’s activities were consistent with its
application. However, the Coalition:
· Included $91,948 in ineligible costs in grant drawdowns
and
· Submitted inaccurate Annual Progress Reports.
To achieve our audit objectives in auditing the Consortium
we:
· Reviewed audit reports and memorandums issued on
grants awarded to Consortium members;
· Reviewed minutes from Consortium meetings;
· Interviewed City staff responsible for facilitating the
Consortium;
· Interviewed HUD staff;
· Reviewed peer reviews performed by members of the
Consortium;
· Interviewed Consortium members; and
· Reviewed consolidated applications for 1997, 1998, and
1999 filed by the Consortium.
We conducted our audit at the following offices:
· Dallas Jewish Coalition
· Housing Crisis Center
· City of Dallas City Hall and Day Resource Center
· Greater Dallas Council on Alcohol and Drug Abuse
· HUD Fort Worth Office
Page 7 2001-FW-1006
Introduction
Audit Period and Sites During our audit, we obtained computer-generated data
from both HUD and the grantees. However, we did not
perform any tests on the validity or reliability of such data
except as noted in the findings and management controls.
We performed fieldwork from June 1999 through April
2001.22 We conducted our audit in accordance with
generally accepted government auditing standards.
22
This includes fieldwork in performing the grantee audits as well as the Continuum audit.
2001-FW-1006 Page 8
Finding 1
The Consortium Misled HUD and
Did Not Effectively Evaluate or
Provide Meaningful Feedback on
Grantee Performance
The Consortium submitted inaccurate applications to HUD and did not take appropriate
measures to ensure its members met the goals of the Continuum of Care concept.
Specifically, the Consortium’s applications contained inaccurate information and
overstated its achievements. Contrary to what the Consortium stated it would do, the
Consortium did not establish a tracking system that would monitor participants; nor did it
distribute monthly reports, highlighting individual client referrals and progress, to its
members. In addition, the Consortium did not have an effective peer review process.
Therefore, it did not uncover the errors or aid members in setting and achieving their
goals. HUD should review the existing Continuum of Care strategy of the Consortium to
ensure that the strategy accurately represents the efforts and plans of the Consortium;
work with the Consortium to strengthen its peer review process; require the Consortium to
implement a tracking system; continue to provide technical assistance to the Consortium as
it works through the process of choosing a lead agency; and assist the Consortium in
formalizing operational requirements for the Consortium, the lead agency, and the
Consortium members.
The Consortium submitted Due to the Consortium supplying inaccurate information
inaccurate information to and overstating its accomplishments, it provided HUD a
HUD. distorted view of the administration of the Consortium.
HUD placed a high priority on a community’s Continuum
of Care strategy. In fact, the ranking of the consolidated
application was based on the description of the strategy.
Therefore, HUD relied upon applicants to provide an
accurate picture of their efforts to organize and maintain the
Continuum. The applications filed by the Consortium
contained inaccurate information and overstated its
achievements.
For instance, each Consortium application since 1996
referred to a tracking system. According to the
applications, the Consortium would track options available
to individuals with respect to specific services available, as
well as provide a record of which agencies the individual
Page 9 2001-FW-1006
Finding 1
had contacted previously. The applications filed from 1996
through 1999 contained the following statements:
1996 Homeless service providers in the city of Dallas
are working toward supplying a range of other
services. Central among these plans is the
development of a centralized intake system…23
1997 Commitment to implement a centralized,
integrated electronic system to link agencies
providing housing and services to homeless
families through a computerized client referral,
tracking, and information system…24
A key part of this year’s Continuum of Care
strategy is to implement a centralized integrated
electronic system to link agencies providing
housing and services to homeless families
through a computerized client referral, tracking,
and information system.25
1998 This Continuum comes forth with a structured
system of client referrals and client tracking
through the Continuum of Care.26
1999 This Continuum comes forth with a structured
system of client referrals and client tracking
through the Continuum of Care (same statement
as in 1998).27
The 1998 and 1999 applications indicated the Consortium
had implemented a tracking system. However, even though
the Consortium indicated it had been working on
implementing a tracking system for over 4 years, the
Consortium did not have such a system in place.
A system of coordinating services and tracking participants’
progress was essential to the success and evaluation of
these programs. Without some way of demonstrating the
success of the programs and their participants, the
23
Dallas Homeless Consortium 1996 Consolidated Application, The Continuum of Care Strategy.
24
Dallas Homeless Consortium 1997 Consolidated Application, Continuum of Care System Under Development.
25
Dallas Homeless Consortium 1997 Consolidated Application, Actions For The Future.
26
Dallas Homeless Consortium 1998 Consolidated Application, Abstract Dallas Continuum of Care.
27
Dallas Homeless Consortium 1999 Consolidated Application, Abstract Dallas Continuum of Care.
2001-FW-1006 Page 10
Finding 1
Consortium and HUD could not objectively evaluate the
effectiveness of its programs. The overall goal of the
Continuum of Care strategy was to assist homeless
individuals and families to make the critical transition from
living on the streets to working and independent living.
During 1996 and 1997, the Consortium received almost $10
million in Continuum of Care grants. However, since
neither the individual grantees nor the Consortium had a
system or process in place to coordinate housing and
services, or to track participant or program success, HUD
did not know if the Consortium and its members utilized
the funds on programs to achieve their basic goal.
We recommend HUD require the Consortium to implement
a tracking system. Further, the Consortium should utilize
any historical data gathered to date.
The City of Dallas Did Not Provide Materials to Members.
While the Consortium developed a common referral and
intake form, the City did not fulfill its statements of
coordinating and providing information to its members. In
addition, while the consolidated applications filed by the
City of Dallas on behalf of the Consortium exhibit efforts
to coordinate and bring together homeless providers, the
City of Dallas could not provide sufficient evidence to
support much of the information in the applications.
The 1998 Consolidated application stated:
“The members of the Collaborative have all signed a
Memorandum of Understanding committing to move
people through the Continuum by formal referrals to
each other, by tracking clients as they go through the
system, and by having ongoing discussions about
client progress. In September, the City of Dallas will
start to collect client information from each agency
and provide a formal report on client referrals and
progress at the end of the month. This system will
avoid duplication of services, highlight individual
client progress, and allow for broad input from a
variety of agencies. Agencies with limited service
capacity will provide a weekly report on their ability to
accept new clients. The report will be provided to all
members who will then be able to make referrals to
Page 11 2001-FW-1006
Finding 1
agencies with open service slots. All Collaborative
Agencies will use common referral forms, release of
information forms, and intake forms. When clients are
referred, a copy of their intake is sent to the agency
with a signed release to share information. Therefore,
the client has one record that details his or her
movement through the components of the Continuum
of Care. The components are linked through the
Collaborative, through the uniform referral and intake
process, and through the data collection and sharing by
the City of Dallas.” 28
Again, HUD wanted this type of coordination between
Consortium members. Because the City never
accomplished its goal, the Consortium did not have “one
record that details [the participant’s] movement through the
components of the Continuum of Care.” HUD should
review the existing Continuum of Care strategy to ensure
the strategy accurately represents the efforts and plans of
the Consortium.
The Consortium Had an Ineffective Peer Review Process.
The peer review process utilized by the Consortium did not
effectively assess members’ performance. However,
according to a Consortium official, the peer review affected
the priority given to an individual application. During a
peer review the review team examined Annual Progress
Reports of each agency under review, met with program
managers and bookkeepers at City Hall, toured the various
programs, and spoke to participants. The review team
prepared a summary of results for each review. However,
in performing the review, the peer review team did not
inspect supporting documentation when reviewing progress
reported by members. As a result of not inspecting
supporting documentation, the peer review of these
grantees did not detect any inaccuracies with the Annual
Progress Reports. As we previously reported, each grantee
submitted inaccurate and unsupported Annual Progress
Reports. It appeared the peer review team echoed
management assertions without attempting to verify them.
As a result, members who inflated results or progress may
28
Dallas Homeless Consortium 1998 Consolidated Application, How the System Facilitates Movement of Homeless Persons
From One Component of the System to Another, and How the Components are Linked.
2001-FW-1006 Page 12
Finding 1
have received a higher ranking than those who reported
accurate information.
Since no agreements exist between the Consortium and its
members, and HUD did not have any regulations governing
the Consortium, the Consortium did not have direct
authority over the members. Therefore, the Consortium
had limited ability to coordinate and direct its members.
However, the Consortium determined the priority of the
individual applications within the consolidated application.
Since HUD awarded grants based on the priority placed on
the programs by the Consortium, under the existing system
it was possible that ineffective and unsuccessful programs
received priority status in the consolidated applications
filed by the Consortium.
We recommend that HUD work with the Consortium to
strengthen its peer review process.
The Consortium Lacked Effective Leadership.
Our audit of the City of Dallas concluded the City of Dallas
failed to administer its homeless grants in accordance with
its grant agreements and federal regulations.29 Specifically,
the City did not: (1) provide and document the matching
supportive services required by the Shelter Plus Care
program; (2) expend its funds timely; (3) file accurate and
consistent Annual Progress Reports; (4) include only
eligible and supported costs in its grant drawdowns; (5)
monitor the participants and their supportive service needs
sufficiently; and (6) perform yearly Housing Quality
Standards inspections for apartments inhabited 1 year or
more. The report recommended HUD discontinue funding
Continuum of Care grants to the City until the City could
demonstrate that it can administer the funds appropriately.
In spite of the problems faced by the City of Dallas in
managing its own grants, it took on a leadership role in the
Consortium as the “lead agency.” As such, the City of
Dallas was responsible for drafting the Continuum of Care
strategy for the Consortium, facilitating the Consortium,
and packaging the actual consolidated application. The
City of Dallas also provided a staff person to act as a liaison
29
Audit Report number 01-FW-251-1002, dated December 13, 2000.
Page 13 2001-FW-1006
Finding 1
and provided funding for mailings, consultants, and other
administrative matters. Due to the conditions noted in this
finding and with the City of Dallas’ administration of its
grants, HUD should continue to provide technical
assistance to the Consortium in order to assist in choosing a
lead agency. Once a lead agency has been determined, its
roles and responsibilities should be formalized. We
recommend HUD provide additional technical assistance to
the Consortium in order to document and implement the
operational requirements for the Consortium and its
members.
On September 5, 2001, we held an exit conference with
Auditee Comments HUD, and they provided their written response (Appendix
A). HUD agreed the Dallas Homeless Consortium’s
applications included inaccurate information and overstated
achievements. However, they believed the use of the word
misled was harsh. HUD did not believe the City or the
Consortium tried to intentionally deceive them.
HUD did not dispute the issues raised in the finding.
However, they did request modifications to the
recommendations.
HUD has not issued any regulations governing the
Continuum of Care organizations. Consequently, HUD has
no authority to direct the Consortium or to determine the
lead agency. In HUD’s opinion, the Consortium needs to
make that determination. Instead of playing an active role
in the removal of the City as the lead agency, HUD
proposed continuing to provide technical assistance to the
Consortium as it works through the process of choosing a
lead agency.
OIG Evaluation of Considering the evidence, the use of the word misled was
appropriate. The applications were prepared in order to
Comments
make the Dallas Homeless Consortium appear as a well-run
organization that had made significant strides in its efforts
to help the homeless. However, there was little evidence to
support this.
2001-FW-1006 Page 14
Finding 1
The draft report included the recommendation that HUD
work with the Consortium to remove the City of Dallas as
the lead agency of the Consortium. However, based on
HUD’s response we revised our recommendation. As HUD
correctly pointed out, they did not issue regulations
governing Continuum of Care organizations. Therefore, it
has no official authority to dictate the lead agency or how
the organization operates.
As a result we modified our recommendation.
Recommendations We recommend HUD:
1A. Review the existing Continuum of Care strategy of
the Consortium to ensure that the strategy accurately
represents the efforts and plans of the Consortium.
1B. Work with the Consortium to strengthen its peer
review process.
1C. Require the Consortium to implement a tracking
system.
1D. Continue to provide technical assistance to the
Consortium as it works through the process of
choosing a lead agency.
1E. Provide technical assistance to the Consortium in
order to document and implement the operational
requirements for the Consortium, the lead agency,
and its members.
Page 15 2001-FW-1006
Finding 1
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2001-FW-1006 Page 16
Management Controls
In planning and performing our audit, we obtained an understanding of the management
controls that were relevant to our audit. Management is responsible for establishing
effective management controls. Management controls, in the broadest sense, include the
plan of organization, methods, and procedures adopted by management to ensure that the
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.
Significant Controls. We determined the following management controls were
relevant to our audit objectives:
· Fair representation of the needs of the community
· Broad participation
· A fair funding process
· Accountability for performance
· Tracking of program progress and participants
Significant Weaknesses. It is a significant weakness if management controls do not
give reasonable assurance that resource use is consistent
with laws, regulations, and policies; that resources are
safeguarded against waste, loss, and misuse; and that
reliable data is obtained, maintained, and fairly disclosed in
reports. As discussed in our finding, we believe the
following items are significant weaknesses in that the
Dallas Homeless Consortium lacks sufficient controls to
ensure:
· A fair funding process
· Accountability for performance
· Tracking of program progress and participants
Page 17 2001-FW-1006
Management Controls
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2001-FW-1006 Page 18
Appendix A
Auditee Comments
Page 19 2001-FW-1006
Appendix A
2001-FW-1006 Page 20
Appendix A
Page 21 2001-FW-1006
Appendix A
2001-FW-1006 Page 22
Appendix B
Distribution
Dallas City Manager
Director, Environmental and Health Services, City of Dallas
Dallas City Auditor
Dallas Homeless Consortium
Principal Staff
Secretary's Representative, 6AS
CFO, 6AF
Director, Accounting, 6AAF
Director, Office of Community Planning & Development, 6FD
Fort Worth ALO, 6AF (2)
CPD ALO, DOT (Room 7220)
Department ALO, FM (Room 2206)
Acquisitions Librarian, Library, AS (Room 8141)
Armando Falcon
Director, Office of Federal Housing Enterprise Oversight
1700 G Street, NW, Room 4011, Washington, D.C. 20515
Sharon Pinkerton
Sr. Advisor, Subcommittee on Criminal Justice, Drug Policy &
Human Resources
B373 Rayburn House Ofc. Bldg., Washington, D.C. 20515
Cindy Fogleman
Subcommittee on General Oversight & Investigations, Room 212
O'Neill House Ofc. Bldg., Washington, D.C. 20515
Stanley Czerwinski
Associate Director, Housing. & Telecommunications Issues
US GAO, 441 G St. NW, Room 2T23, Washington, DC 20548
Steve Redburn
Chief, Housing Branch, OMB
725 17th Street, NW, Room 9226, New Exec. Ofc. Bldg., Washington, D.C. 20503
The Honorable Fred Thompson
Chairman, Committee on Govt Affairs,
340 Dirksen Senate Office Bldg.
U.S. Senate, Washington, D.C. 20510
The Honorable Joseph Lieberman
Ranking Member, Committee on Govt Affairs,
706 Hart Senate Office Bldg.
U.S. Senate, Washington, D.C. 20510
Page 23 2001-FW-1006
Appendix B
The Honorable Dan Burton
Chairman, Committee on Govt Reform,
2185 Rayburn Building
House of Representatives, Washington, D.C. 20515-6143
Henry A. Waxman
Ranking Member, Committee on Govt Reform,
2204 Rayburn Bldg.
House of Rep., Washington, D.C. 20515-4305
Andrew R. Cochran
Sr. Counsel, Committee on Financial Services
2129 Rayburn, HOB
House of Rep., Washington, D.C. 20510
2001-FW-1006 Page 24
Dallas Homeless Consortium Continuum of Care Dallas, Texas
Published by the Department of Housing and Urban Development, Office of Inspector General on 2001-09-21.
Below is a raw (and likely hideous) rendition of the original report. (PDF)