oversight

Los Angeles Homeless Services Authority, El Monte Youth Development Center, Supportive Housing Program Grant (CA16B97-0021), Los Angeles, California

Published by the Department of Housing and Urban Development, Office of Inspector General on 2001-03-23.

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

                                                      U.S. Department of Housing and Urban Development
                                                                     Office of Inspector General
                                                                                      Pacific/Hawaii District
                                                                       450 Golden Gate Avenue, Box 36003
                                                                      San Francisco, California 94102-3448




                                                                                  Audit Memorandum
                                                                                       2001-SF-1803

March 23, 2001




MEMORANDUM FOR:                       William Barth, Director
                                      Office of Community Planning and Development, 9DD

                                      “SIGNED”
FROM:                                 Mimi Y. Lee
                                      District Inspector General for Audit, 9AGA

SUBJECT:                              Los Angeles Homeless Services Authority
                                      El Monte Youth Development Center
                                      Supportive Housing Program Grant (CA16B97-0021)
                                      Los Angeles, California


As part of a nationwide review of HUD’s Continuum of Care Program, we audited the subject grant
awarded to the Los Angeles Homeless Services Authority (LAHSA) for the 1997 Supportive Housing
Program (SHP) operated by the El Monte Youth Development Center (El Monte). El Monte carried
out all grant activities as a sub-grantee of LAHSA. The purpose of our audit was to determine whether
LAHSA and El Monte operated the Continuum of Care grant in accordance with the approved
application as well as HUD and other federal requirements.

                                           SUMMARY

We concluded that El Monte did not implement its activities consistent with its application.
Specifically, El Monte admitted ineligible participants and participants whose eligibility was not
adequately documented, did not accomplish program goals or maintain evidence of measurable results,
did not maintain financial records that support specific grant expenditures, did not follow Federal
procurement procedures in awarding contracts for services, charged ineligible costs to the grant, and
failed to remit interest income earned on federal funds to the US Treasury Department as required.

These problems occurred because El Monte hired unqualified staff and because management did not
understand or disregarded the applicable Federal or contractual requirements. As a result, El Monte
                                                                    Los Angeles Homeless Services Authority
Audit Memorandum                                                    El Monte Youth Development Center

has spent at least $656,845 ($80,639 + $576,206) of HUD funds on costs that did not benefit or may
not have benefited the intended program participants.

LAHSA did not actually incur any of the costs in question. Nevertheless, according to its grant
agreement with HUD, LAHSA agreed “to comply with all requirements of its grant agreements and to
accept responsibility for such compliance by any entities to which it makes grant funds available.” The
grant agreement also required LAHSA to provide sub-grantee monitoring, but LAHSA had not done
any onsite monitoring of any sub-grantees until October 2000 although many of the sub-grantees had
been operating and receiving funding for years. Further, LAHSA did not conduct formal monitoring of
the sub-grantees prior to awarding renewal grants. Our recommendations for corrective actions and for
reimbursement to HUD are therefore directed to LAHSA.

      Description of Expenditure                       Ineligible                    Unsupported
 Questionable Program Participants                      $70,236                        $93,648
 Not Supported as Allocable to TLC                                                     482,558
 Unallowable Interest Earned                             1,005
 Miscellaneous Ineligible Costs                          2,507
 Excessive Administrative Costs                          6,891
        Totals                                          $80,639                        $576,206

                                        BACKGROUND

Title IV of the Stewart B. McKinney Homeless Assistance Act authorized the Supportive Housing
Program (SHP). The program is designed to promote the development of supportive housing and
services, including innovative approaches to assist homeless persons in the transition from homelessness,
and to promote the provision of supportive housing to homeless persons to enable them to live as
independently as possible. Eligible activities include:

        •   Transitional housing,
        •   Permanent housing for homeless persons with disabilities,
        •   Innovative housing that meets the immediate and long-term needs of homeless persons, and
        •   Supportive services for homeless persons not provided in conjunction with supportive
            housing.

LAHSA is a California public nonprofit corporation and the primary administrative agency for
distributing government funding for Supportive Housing Programs in Los Angeles County. El Monte is
a private nonprofit corporation.

The focus of our audit was LAHSA’s 1997 $1,340,518 Supportive Housing Grant (CA16B97-0021)
for El Monte to provide transitional housing, supportive services, and case management. El Monte
referred to this program as their Transitional Living Care (TLC) program. However, due to El Monte’s



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                                                                  Los Angeles Homeless Services Authority
Audit Memorandum                                                  El Monte Youth Development Center

failure to properly segregate and account for different funding sources, in some instances, our review
overlapped other grants as summarized below:

 Funding Source        Program Name                     Type of Services               Total Awarded
 HUD SHP Grant        Transitional Living   Transitional housing, supportive             $1,340,518
 (CA16B97-0021)       Care (TLC)            services, and case management
 HUD SHP Grant        Pathways              Housing for Domestic Violence victims          $746,473
 (CA16B800-022)
 HUD SHP Grant        Multi Services        Intake Center for individuals with needs       $950,786
 (CA16B97-0062)       Center                ranging from housing to job placement

 HUD SHP Grant        Outreach Team         Substance abuse program and homeless           $601,066
 (CA16B800-030)                             assistance
                            TOTALS                                                        $3,638,843

Requirements of the Grant

The subject grant agreement (CA16B97-0021) incorporated the grant application, which specified that
El Monte would provide transitional housing and supportive services to homeless adolescents and young
adults. Under the grant agreement, El Monte would perform most of the grantee duties while LAHSA
would act as a pass-through entity performing administrative duties. LAHSA and El Monte agreed to
meet the following performance measures:

   •   200 persons will enter the program during the first three grant years;
   •   100% of the residents will develop a comprehensive case management plan;
   •   At the end of three months, 90% of the residents will have a source of income from employment
       or public assistance;
   •   At the end of four months, 90% of the residents will have successfully initiated a money
       management plan and two months later, 90% of them will have move-in costs;
   •   At the end of six months, 80% of the residents will be employed with a job, 90% of them will
       maintain their jobs six months later;
   •   At the end of three months, 100% of the residents will participate in household chores;
   •   At the end of three months, 100% of the residents will have completed a mental health care
       assessment, 50% of them will voluntarily comply with treatment one month later;
   •   At the end of three months, 100% of the residents will have completed a medical health care
       assessment, 50% of them will voluntarily comply with treatment one month later;
   •   At the end of six months, 40% of the residents will have received substance abuse counseling,
       90% of them will maintain their sobriety three months later;
   •   At the end of six months, 60% of the residents will have received AIDS testing or counseling;
   •   At the end of six months, 50% of the residents will have received crisis intervention by the peer
       counselor;


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                                                                         Los Angeles Homeless Services Authority
Audit Memorandum                                                         El Monte Youth Development Center

    •   60% of the residents will successfully transition to permanent housing and 80% of them will
        maintain their housing a year later; and
    •   20% of the residents will successfully transition into service-enriched permanent housing and
        80% of them will maintain their housing a year later.

                            OBJECTIVE, SCOPE AND METHODOLOGY

The overall objective of our audit was to determine whether LAHSA and El Monte operated the
Continuum of Care grant in accordance with the approved application as well as HUD and other federal
requirements. To accomplish our objectives, we interviewed HUD, LAHSA and El Monte officials;
visited the transitional housing location; reviewed LAHSA’s policies and procedures manual; and
reviewed the grant application, grant agreement, technical submission and El Monte’s annual progress
report, financial records, and participant files. We also reviewed applicable criteria including Office of
Management and Budget (OMB) Circular A-122, “Cost Principles for Non-Profit Organizations.”

The audit generally covered the period from January 1, 1999 through October 31, 2000. We
conducted the audit in accordance with generally accepted government auditing standards.

                                            REVIEW RESULTS

El Monte admitted ineligible participants and participants whose eligibility was not adequately
documented into the transitional housing program.

El Monte did not maintain adequate documentation regarding the prior living situations of the program
participants. A total of 51 participants entered the program during the first two grant years. We
reviewed 100 percent of the participant files and determined 21 of 51 participants were ineligible or
their eligibility was not adequately documented. Although El Monte’s financial records do not show the
actual costs per participant, we estimated El Monte spent $7,8041 per participant for supportive
services during the period.

Based on our calculation, El Monte spent $70,236 ($15,608 + $54,628) in supportive services for the
ineligible participants and $93,648 for participants who may not have been eligible as identified below:

    •   2 of 21 participants exceeded the age limit established in the grant application and were
        therefore ineligible for the TLC Program ($15,608). As stated in their application, the
        objective of the TLC Program is to provide transitional housing and supportive services to youth
        ages 16 to 24 who have been emancipated from foster care and group homes and are not quite



1
 SHP supportive services amount awarded for 3-year grant period ($651,297) divided by 36 months ($18,092)
multiplied by 22 months reviewed ($398,024) and divided by 51 program participants equals the supportive service
cost per participant ($7,804).


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                                                                   Los Angeles Homeless Services Authority
Audit Memorandum                                                   El Monte Youth Development Center

        ready to live on their own. The two participants in question were aged 35 and 52 at the time of
        their placement in the TLC Program.

    •   7 of 21 participants lived with family and friends prior to placement and stated they left home to
        become more independent. These individuals do not qualify as homeless and are ineligible for
        the TLC Program ($54,628). The SHP Desk Guide specifically classifies people who are living
        with relatives or friends as ineligible.

    •   12 of 21 participants submitted incomplete applications to the TLC staff so we could not
        determine their eligibility ($93,648). The SHP Desk Guide states, “grantees must maintain
        adequate documentation to demonstrate the eligibility of persons served by SHP funds.”
        Homelessness eligibility documentation for these 12 participants was so incomplete that the
        prior living situation was not even identified.

HUD’s Supportive Housing Program (SHP) Desk Guide, which was released in April 2000, requires
the grantees to maintain adequate written documentation to demonstrate the eligibility of the participants.
LAHSA and all of its grant recipients have received HUD training on SHP requirements including
participant eligibility and documentation of eligibility. Prior to the release of the Desk Guide, HUD
training focused on homeless eligibility. Subsequent HUD training has covered both participant eligibility
and documentation of homelessness.

In our opinion, the SHP requirements were not followed because El Monte hired unqualified staff to
oversee and operate the TLC Program and/or because the staff was unaware of or disregarded the
applicable requirements. As a result, El Monte admitted ineligible participants into the program thereby
limiting the funding which would have been available for truly qualified applicants.

The grant agreement required LAHSA to provide onsite monitoring of the TLC Program. Since
LAHSA did not do any onsite monitoring of the TLC Program, the participant eligibility problem was
not identified and LAHSA could not be assured that the intended population was served.

El Monte did not accomplish program goals and/or could not support reported
accomplishments.

HUD requires grantees to submit annual progress reports (APRs) on the goals listed in their
applications. HUD uses this information to evaluate the successfulness of the programs. Although the
required report submitted by El Monte to LAHSA and HUD claimed accomplishment of all program
goals, El Monte did not maintain support for the reported accomplishments.

El Monte did not maintain participant files or other summary records in a manner, which facilitated
reconfirmation of its reports. They did not keep lists of goals met by the participants and staff did not
track the participants’ progress anywhere besides the participant files. To report El Monte’s
accomplishments to LAHSA, the Program Manager manually went through the participant files and


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                                                                   Los Angeles Homeless Services Authority
Audit Memorandum                                                   El Monte Youth Development Center

counted the number of participants meeting program goals. However, no verifiable record of this
tabulation was maintained.

One program goal was to provide each participant with an individual plan that outlined what the
participant hoped to accomplish. Half of the files we reviewed contained documentation identifying the
plans but none of the files reviewed documented the actual accomplishment of the participants’ plans.

In addition, El Monte did not provide the level of services it proposed in its application. The application
stated transitional housing services for 200 homeless youth would be provided by the end of the grant
period. To accomplish this, El Monte would have to serve approximately 66 participants per grant
year. El Monte’s progress report indicated 33 participants were served during year 1 and their
program files indicated only 16 participants were served through October of the second grant year.
One reason for this shortfall was El Monte’s failure to keep the TLC facility filled to maximum capacity
as stated in its application. The Program Manager said this was because she was very selective and
carefully considered the background and personality of the applicants before accepting them into the
program.

Also, El Monte did not track participants after they left the Program. El Monte did not formally follow-
up on participants once they left the program as required by two of its goals. One goal required that
60% of the participants would transition into permanent housing and 80% of them would maintain their
housing a year later. El Monte reported the accomplishment of this goal although no documentation
existed of participant contacts after they left the program. The other goal similarly required 20% of the
participants to successfully transition into service-enriched permanent housing with 80% of them
maintaining their housing a year later. El Monte staff acknowledged they did not meet this goal. The
Case Manager said it was too difficult to get information from participants once they left the program.

The Program was not implemented as stated in El Monte’s Technical Submission and application, at
least in part, because unqualified program staff were hired. The Technical Submission specifically states
the qualifications of their program staff would be as follows:

     •   Program Manager and Case Managers should possess a Master’s Degree in Social Work or
         a related field or a combination of education and work experience;

     •   Job Development Specialist, Housing Placement Specialist, and Youth Peer Counselor should
         possess a Bachelors Degree in Social Work or a related field or a combination of education
         and experience; and

     •   Weekend Program Staff should possess an Associates Degree in Social Work or a related
         field or a combination of education and experience.

The Program Manager, Case Manager, Job Development Specialist and the Weekend Program Staff
all lacked the qualifications required to implement the specialized supportive services. El Monte’s


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                                                                 Los Angeles Homeless Services Authority
Audit Memorandum                                                 El Monte Youth Development Center

management hired people for these positions who did not have the required specialized training and
experience.

The Program’s success depends upon the individual participants meeting the goals set during the initial
assessment and on El Monte meeting the goals stated in the grant application. El Monte made
inaccurate and unsupported claims of goal accomplishments in their APR and LAHSA relied on these
representations when they awarded El Monte a renewal grant of $902,991.

El Monte’s financial records did not support grant expenditures and some expenditures did
not comply with Federal procurement regulations.

The TLC Program financial records did not accurately support or segregate grant expenditures.
Although El Monte received HUD funding from four different SHP grants to administer four different
programs, all funding for these programs was maintained in one general checking account without
proper accounting for individual SHP grant expenditures as required. Therefore, at the time of our
audit, we could not determine the actual TLC Program expenditures.

Although financial statements prepared by El Monte’s Independent Public Accountant (IPA) show total
expenses of $1,282,143 for the TLC Program through October 31, 2000, we were only able to verify
$799,585 of these expenses as applicable to the TLC Program. Based on our review of the IPA’s
financial statements and 100 percent of the related supporting documentation, we determined that
expenses totaling $482,558 ($1,282,143 - $799,585) were not supported by documentation justifying
their eligibility or allocability to the TLC Program.

Program Expenditures as of October 2000           Supported Expenses        Unsupported Expenses
Acquisition & Rehabilitation Costs                    $400,000
Operating Costs                                         52,832
Costs for Supportive Services                          335,689
TLC Program Van Lease (22 months)                       11,064
Not Supported as Allocable to TLC                                                    482,558
Total Program Expenditures                              $799,585                    $482,558

HUD’s SHP Desk Guide states “the lead agency has the contractual responsibility for ensuring that the
project described in the application and technical submission is successfully carried out. A lead
agency’s responsibility encompasses oversight for every aspect of the project, including ensuring funds
expended are for eligible activities.” The SHP Desk Guide also requires all grantees and/or their
recipients to provide complete, up-to-date project records and financial documentation to demonstrate
eligibility of project expenses. El Monte’s management did not follow the applicable requirements.

In addition, El Monte did not comply with contractual obligations and Federal regulations when
obtaining some services for the TLC Program. The Executive Director was unaware of the guidelines
identified in the 1997 SHP Contract with LAHSA and Title 24 Code of Federal Regulations (CFR)

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                                                                        Los Angeles Homeless Services Authority
Audit Memorandum                                                        El Monte Youth Development Center

Section 85.36 for solicitation of bids and procurement of required services, respectively. The Executive
Director stated she used contractors recommended by the City of El Monte to perform services for the
TLC Program rather than advertising the job, soliciting bids, and selecting the lowest bidder as required.
As a result, contractors with ties to the City were given preferential treatment. In addition, LAHSA and
HUD could not be assured that the fees for contracted services were fair and equitable.

El Monte charged ineligible costs to the grant and failed to remit interest income.

El Monte charged the TLC Program a total of $2,507 in proscribed expenses. OMB Circular A-122
specifically prohibits grantees from using grant funds to pay for memberships, subscriptions, professional
activity costs, fines and penalties and alcoholic beverages. However, in reviewing the program expense
checks we found unallowable costs to the grant for the following purposes:

     •   Fines and penalties assessed on delinquent property taxes to the County of Los Angeles for
         $2,241;

     •   Membership dues to the Soroptimist International Women’s Charitable Organization for two
         employees for $150 ($75 each); and

     •   Alcoholic beverages for a Sweetheart’s Program sponsored by El Monte for $116.

In addition, El Monte has charged excessive administrative costs totaling $6,891 ($70,725 - $63,834)
to the TLC Program. El Monte’s grant of $1,340,518 for the TLC Program was to be allocated as
follows according to the Grant Agreement:

                   Description                                                      Amount
                   Acquisitions                                                  $ 400,000
                   Supportive Services                                              651,297
                   Operating Costs                                                  225,387
                   Administrative                                                    63,834
                   Total                                                         $1,340,518

The $63,834 grant provision for administrative costs is the maximum allowed by regulation (24 CFR
583.135) based on five percent of the total three-year grant. We found El Monte had already recorded
administrative costs of $70,7252 as of October 31, 2000 with a full year of the grant remaining.

Further, El Monte made regular monthly draws of the grant, which were deposited into an interest-
bearing account and transferred the funds into the general checking account when needed. El Monte’s
records show they earned a total of $1,105 in interest on HUD SHP funds for the TLC Program.

2
 Represents recorded administrative costs although only $44,323 of El Monte’s draws had been classified as
administrative expenses per LOCCS.


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                                                                Los Angeles Homeless Services Authority
Audit Memorandum                                                El Monte Youth Development Center

Regulation 24 CFR 85.21(i) states, “grantees and sub-grantees shall promptly, but at least quarterly
remit interest earned on advances to the Federal agency. The grantee or sub-grantee may keep interest
amounts up to $100 per year for administrative expenses.” There is no evidence of El Monte returning
any of the interest earned to HUD.

                      AUDITEE COMMENTS AND OIG EVALUATION

Advance copies of the audit report were provided to LAHSA and El Monte for their review and
comment and our proposed recommendations were discussed with officials of both agencies at an exit
conference on March 20, 2001. LAHSA’s March 1, 2001 written response pointed out some possible
technical or typographical errors in the draft but took no exception to the actual issues we reported.
The March 5, 2001 written response from El Monte also took no exception to the information in the
audit report. At the exit conference, LAHSA and El Monte officials reviewed and accepted the
proposed recommendations in a very positive manner and indicated their intentions to work together to
resolve all of the reported problems.

                                    RECOMMENDATIONS

We recommend HUD require LAHSA to:

1A.    Conduct programmatic and financial monitoring of all sub-grantees and document follow-up
       actions resulting from the site visits.

1B.    Ensure El Monte obtains and verifies the necessary information to determine participant
       eligibility.

1C.    Assist El Monte in developing and implementing necessary procedures and systems to collect
       relevant data and accurately report on its performance.

1D.    Perform in-depth reviews of all grants awarded to El Monte on a grant-by-grant basis to ensure
       supporting documentation is maintained and all costs are eligible and documented.

1E.    Require El Monte to revise their accounting systems to properly account for individual grant
       expenses on a grant-by-grant basis prior to receiving additional funding.

1F.    Reimburse HUD for the $80,639 of ineligible costs incurred by El Monte.

1G.    Require El Monte to provide documentation supporting the eligibility and allocability of
       $576,206 in unsupported costs, and reclassify or reimburse HUD for any costs, which cannot
       be documented as eligible costs specifically applicable to the TLC Program grant.

                                           *   * * * *


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                                                                  Los Angeles Homeless Services Authority
Audit Memorandum                                                  El Monte Youth Development Center



Within 60 days, please give us a status report on the recommendations stating (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 furnish us copies of any correspondence or directives related to this review.

If you have any questions concerning this report, please call Ruben Velasco, Assistant District Inspector
General for Audit, at (213) 894-8016.




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                                                               Los Angeles Homeless Services Authority
Audit Memorandum                                               El Monte Youth Development Center

                                                                                     APPENDIX A

                                        DISTRIBUTION

Secretary’s Representative, California State Office, 9AS
Senior Community Builder, Los Angeles Office, 9HS
Director, Community Planning and Development, 9DD
Primary Field Audit Liaison Officer, 6AF (2)
Deputy Secretary, SD (Rm. 10100)
Acting, Chief of Staff, S (Rm. 1000)
Office of Administration, AA (Rm. 10110)
Assistant Secretary for Congressional & Intergovernmental Relations, J (Rm. 10120)
Office of Public Affairs, W (Rm. 10132)
Deputy Assistant Secretary for Administrative Services, Office of the Executive
        Secretariat, AX (Rm. 10139)
Deputy Assistant Secretary for Intergovernmental Relations, JI (Rm. 10234)
Deputy Chief of Staff, S (Rm. 10222)
Deputy Chief of Staff for Policy, S (Rm. 10226)
Deputy Chief of Staff for Programs, S (Rm. 10226
Senior Advisor to the Secretary, S (Rm. 10222)
Special Assistant for Inter-Faith Community Outreach, S (Rm. 10222)
Executive Officer for Administrative Operations and Management, S (Rm. 10220)
General Counsel, C (Rm. 10214)
Assistant Secretary for Community Planning and Development, D (Rm. 7100)
Assistant Secretary for Field Policy and Management (Rm. 7106) (2)
Assistant Secretary for Policy Development and Research, R (Rm. 8100)
Assistant Secretary for Housing/Federal Housing Commissioner, H (rm. 9100)
Assistant Secretary for Fair Housing and Equal Opportunity, E (Rm. 5100)
Director, Office of Departmental Equal Employment Opportunity, U (Rm. 5130)
Chief Procurement Officer, N. (Rm. 5280)
Assistant Secretary for Public and Indian Housing
Director, Office of Departmental Operations and Coordination, I (Rm. 2124)
Office of the Chief Financial Officer, (Rm. 2202)
Chief Information Officer, Q (Rm. P8206)
Acting Director, Enforcement Center, V, Portals Building
Acting Director, Real Estate Assessment Center, X 2180 Maryland Avenue, SW,
        Suite 800
Director, Office of Multifamily Assistance Restructuring
Deputy Chief Financial Officer for Finance, FF (Rm. 2202)
Director, Office of Budget, FO (Rm. 3270)
Headquarters Audit Liaison Officer, Helen M. Stackhouse, HQC (Rm. 6232) (2)
Departmental Audit Liaison Officer, FM (Rm. 2206) (2)


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                                                            Los Angeles Homeless Services Authority
Audit Memorandum                                            El Monte Youth Development Center

Acquisitions Librarian, Library, AS (Rm. 8141)

Director, Office of Federal Housing Enterprise Oversight, 1700 G. Street, NW,
        Room 4011 Washington, DC 20552
Frank Edrington, Deputy Staff Director, Counsel, Subcommittee on Criminal Justice,
        Drug Policy & Human Resources, B 373 Rayburn House Office Building,
        Washington, DC 20515
Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212, O’Neil
        House Office Building, Washington, DC 20515
Stanley Czerwinski, Associate Director, Resources, Community and Economic
        Development Division, US General Accounting Office, 441 G Street NW, Room
        2T23, Washington, DC 20548
Steve Redburn, Chief Housing Branch, Office of Management and Budget, 725 17th
        Street, NW, Room 9226, New Executive Office Building, Washington, DC 20503
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs,
        706 Hart Senate Office Building, United States Senate, Washington, DC 20501
The Honorable Joseph Lieberman, Ranking Member, Committee on Government Affairs,
        706 Hart Senate Office Building, United States Senate, Washington, DC 20510
The Honorable Dan Burton, Chairman, Committee on Government Reform,
        2185 Rayburn Building, House of Representatives, Washington, DC 20515
The Honorable Henry A. Waxman, Ranking Member, Committee on Government
        Reform, 2204 Rayburn Bldg., House of Representatives, Washington, DC 20515
Mitchell Netburn, Executive Director, Los Angeles Homeless Services Authority
        548 South Spring Street, Suite 400, Los Angeles, CA 90013
Deborah Regan, Executive Director, El Monte Youth Development Center
        3800 Penn Mar, El Monte, CA 91732




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