oversight

City of Worcester, Worcester, Massachusetts Community Development Block Grant Program

Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-03-27.

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

   AUDIT REPORT




   CITY OF WORCESTER
WORCESTER, MASSACHUSETTS

COMMUNITY DEVELOPMENT
 BLOCK GRANT PROGRAM

        2002-BO-1001

      MARCH 27, 2002

 OFFICE OF AUDIT, NEW ENGLAND
    BOSTON, MASSACHUSETTS
                                                                Issue Date
                                                                       March 27, 2002
                                                               Audit Case Number
                                                                          2002-BO-1001




TO: James Barnes, Director, Office of Community Planning and Development, 1AD



FROM:     Barry L. Savill, District Inspector General, Office of Audit, 1AGA


SUBJECT:       City of Worcester
               Community Development Block Grant Program
               Worcester, Massachusetts

We performed an audit of the City of Worcester, Massachusetts (Grantee) Community
Development Block Grant (CDBG) Program. Our objective was to determine whether the
Grantee’s reorganization of the former Office of Planning and Community Development was
effective and allowed the Grantee to fulfill its CDBG Program responsibilities. Specific audit
objectives included determining whether the Grantee: (1) carried out its CDBG activities in an
economical, efficient, and effective manner; (2) complied with the CDBG Program requirements,
laws and regulations; and (3) maintained adequate controls to ensure compliance with HUD
regulations.

Although the Grantee generally utilized its CDBG funds in an efficient and effective manner, we
identified problems with the administration of the Program. The report’s finding indicates that
the Grantee improperly allocated salaries and related expenses as direct costs to the CDBG
Program resulting in significant unsupported and ineligible costs.

Within 60 days, please provide us 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 furnish us with copies of any correspondence or directives issued as a
result of this audit.

If you have any questions, please contact our office at (617) 994-8380.
Management Memorandum




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2002-BO-1001              Page ii
Executive Summary
We conducted an audit of the Community Development Block Grant (CDBG) Program awarded
to the City of Worcester, Massachusetts (Grantee). This audit was requested by the HUD
Massachusetts State Office, Office of Community Planning and Development (CPD). CPD
officials expressed concern with the Grantee’s reorganization of its former Office of Planning
and Community Development (OPCD), and OPCD’s responsibility for the administration of the
CDBG Program.

The primary objective of our audit was to determine whether the reorganization of OPCD was
effective, and allowed the Grantee to maintain its ability to follow HUD CDBG requirements.
Specifically, our audit determined whether the Grantee:

       ·   Carried out its CDBG activities in an economical, efficient, and effective manner;

       ·   Complied with the CDBG Program requirements, laws and regulations; and

       ·   Maintained adequate controls to ensure compliance with HUD regulations.



                                     Through our observation and the interviews conducted
   Audit Results
                                     during our review, we determined that, in general, the
                                     reorganization has not negatively affected the Grantee’s
                                     ability to efficiently and effectively implement its CDBG
                                     Program. At the present time, however, the reorganization
                                     is still underway, and a final determination as to any long-
                                     term effect on the Grantee’s ability to administer its CDBG
                                     Program cannot be made until this process is complete.

                                     The reorganization of OPCD was initiated in February
                                     2001. OPCD, which had administered the Grantee’s
                                     CDBG Program, was eliminated as a Grantee department.
                                     In its place, two new offices were established: the
                                     Executive Office of Neighborhood Services (EONS) and
                                     the Executive Office of Economic Development (EOED).
                                     EONS is currently responsible for administering the
                                     Grantee’s CDBG Program. EOED addresses economic
                                     development and planning. Grantee personnel in both
                                     EONS and EOED indicated that they generally expect the
                                     reorganization to enhance the Grantee's ability to
                                     effectively and efficiently implement its CDBG Program
                                     through increased accountability and monitoring. Through
                                     EONS and EOED, the Grantee provides CDBG funds to
                                     various City Departments and approximately 40
                                     subrecipients. One of the programs managed by EONS is
                                     the Worcester Housing Improvement Program (WHIP).

                                         Page iii                                   2002-BO-1001
Executive Summary


                    EOED manages several programs including the Economic
                    Development (ED) Program.

                    The Grantee does not have a proper allocation plan for staff
                    salaries. The Grantee operates with a Program Year of July 1
                    to June 30. During its Program Years 25 and 26, (July 1,
                    1999 to June 30, 2001), the Grantee charged $710,031 in
                    salaries, $113,570 in fringe benefits and $77,746 in operating
                    overhead to its WHIP and ED Program. The WHIP and the
                    ED Program are managed by EOED and EONS. The charges
                    for fringe benefits and operating overhead were based on
                    staff salaries.

                    Because the Grantee does not have a basis for its allocation
                    plan, the entire amount of $901,347 is questionable.
                    Interviews with the WHIP and the ED Program staff and
                    analysis of their job duties showed that some of their duties
                    were administrative in nature. These salaries should have
                    been identified as administrative costs or costs of other
                    programs instead of direct costs to the WHIP and the ED
                    Program. However, there are consequences for charging
                    administrative costs to the program. Salaries and related
                    costs for Planning and Administrative Costs are limited to 20
                    percent of the CDBG grant awarded plus Program Income,
                    by statute (24 CFR 570.200(g)).

                    Separate from the administrative charges to the WHIP and
                    the ED Program, the Grantee charged other costs of
                    $2,180,161 to CDBG Planning and Administrative Costs.
                    The $2,180,161 represents 18.7 percent of the $11,654,834
                    CDBG grant awards, plus Program Income for Program
                    Years 25 and 26. Planning and Administrative Costs are
                    limited to 20 percent of the subtotal of the CDBG Grant
                    and Program Income.

                    Proper allocation of the administrative type salaries charged
                    to the WHIP and the ED Program could cause the Grantee
                    to exceed its 20 percent statutory limitation for Planning
                    and Administrative Costs. Salaries in excess of the 20
                    percent administrative cap would be ineligible.

                    Using criteria defined under:

                    1) OMB Circular A-87, Attachment B, Section (11)(h)(4)
                        and (h)(5) which requires the distribution of salaries for

2002-BO-1001            Page iv
                                                               Executive Summary


                       employees working on multiple activities or cost
                       objectives to be supported by personnel activity reports or
                       equivalent documentation,

                  2) OMB Circular A-87, Attachment A, Section (c)(1) which
                     states costs must be necessary and reasonable for the proper
                     and efficient performance and administration of Federal
                     awards, and adequately documented, and

                  3) 24 CFR 570.206(a)(1) which defines administrative costs;

                  we believe $331,386 in costs to be ineligible as direct costs to the
                  CDBG Program. The remaining $569,961 ($901,347- $331,386)
                  we believe to be unsupported.

                   Description                   Unsupported    Ineligible     Total
                   Salaries                      $424,073      $285,958      $710,031
                   Fringe Benefits                 68,142         45,428      113,570
                   Ordinary Maintenance            77,746               0      77,746
                   Total                         $569,961      $331,386      $901,347

                  The Grantee believes it will be able to support the majority of the
                  questioned costs. The Grantee disagrees with our interpretation of
                  what constitutes an administrative function and what constitutes a
                  direct cost. Nonetheless, the Grantee acknowledged the need to
                  update its current allocation, but is awaiting the final
                  determination from CPD identifying what constitutes Planning
                  and Administrative Costs. Once resolved, the Grantee intends to
                  perform an analysis of their operations and revise their allocation.

                  We are recommending that the Grantee establish and submit for
Recommendations   HUD approval an appropriate method for allocating direct and
                  indirect costs in accordance with Federal Cost Principles for
                  implementation retroactive to July 1, 2001. In addition, we
                  recommend that the Grantee provide sufficient documentation to
                  support the eligibility and amount of its costs, or reimburse the
                  CDBG Program with non-Federal funds. We recommend that
                  the Grantee reimburse the CDBG Program from non-Federal
                  funds for any amounts in excess of the 20 percent statutory
                  imitation imposed on CDBG Planning and Administrative Costs.

                  CPD should continue to monitor the Grantee through its
                  regularly scheduled monitoring reviews, as the Grantee
                  progresses with the implementation and adjustment of its
                  reorganization.




                        Page   v                                        2002-B0-1001
Executive Summary


                    We discussed the finding with the Grantee during the
 Findings and       course of the audit. An exit conference was held at the
 Recommendations    Grantee on January 11, 2002. On February 15, 2002, we
 Discussed          provided the Grantee a copy of the draft audit report. The
                    Grantee provided comments on March 8, 2002 and
                    generally disagreed with the contents of the report. Due to
                    its voluminous content, the Grantee’s entire response was
                    forwarded to CPD under a separate letter. We included
                    pertinent comments of the Grantee’s response in the
                    Finding section of this report and Appendix C.




2002-BO-1001            Page vi
Table of Contents
Management Memorandum                                           i



Executive Summary                                             iii



Introduction                                                   1



Findings
  1. Costs Improperly Allocated to the Community
     Development Block Grant Program                          7



Management Controls                                          21



Appendices
   A Schedule of Ineligible and Unsupported Costs            23


   B Post-Reorganization Charts                              25


   C Auditee Comments                                        27

   D Distribution                                            41




                             Page vii               2002-BO-1001
Table of Contents


Abbreviations

CDBG            Community Development Block Grant
CFR             Code of Federal Regulations
CPD             Community Planning and Development
ED              Economic Development
EOED            Executive Office of Economic Development
EONS            Executive Office of Neighborhood Services
Grantee         City of Worcester, Massachusetts
HUD             U. S. Department of Housing and Urban Development
OIG             Office of Inspector General
OMB             Office of Management and Budget
OPCD            Office of Planning and Community Development
WHIP            Worcester Housing Improvement Program




2002-BO-1001                           Page viii
Introduction
The Community Development Block Grant (CDBG) Program was established by Title I of the
Housing and Community Development Act of 1974 to assist entitlement grantees in the
development of viable urban communities. Grantees use CDBG funds to develop decent
housing, suitable living environment, and economic opportunity principally for low- and
moderate-income individuals. HUD provides grants to states and local governments as
determined by a statutory formula.

HUD regulations require that CDBG funds be used for eligible activities with the goal of
accomplishing at least one of the following national objectives of the Program:

       (1) to benefit low- and moderate-income individuals;

       (2) to aid in the prevention or elimination of slums and blight; or

       (3) to meet other community development needs having particular urgency.

The City of Worcester, Massachusetts (Grantee) is an entitlement recipient of the CDBG
Program and operates under a City Manager form of government. The current City Manager,
Thomas Hoover, is the official responsible for the Grantee’s CDBG Program. Until February
2001, the Grantee’s former Office of Planning and Community Development (OPCD)
administered the CDBG Program. As of February 2001, the Worcester City Council adopted a
comprehensive reorganization plan involving the various city agencies responsible for economic
development and neighborhood services. The plan identified that its primary purpose was to
focus the Grantee’s existing resources to achieve a higher level of performance in the areas of
economic development, neighborhood services and geographic information systems.

This plan divided the duties and responsibilities of the OPCD among three city agencies: (1) a
new office entitled the Executive Office of Economic Development (EOED); (2) a new office
entitled the Executive Office of Neighborhood Services (EONS); and (3) the Information
Services Department. The EOED is a combination of the economic development and planning
sections of the former OPCD and the Development Office from the City Manager’s Office. The
EONS consists of the Public Services, Housing, Grants and Office Management sections of
OPCD. The Geographic Information System, previously handled by OPCD, became the
responsibility of the Information Services Department hereby enabling all City Departments and
the public to gain on-line access to public geographic data. The EONS is currently responsible
for administering the CDBG Program and is headed by the Assistant City Manager, Paul LaCava.




                                          Page 1                                  2002-BO-1001
Introduction


The chart below depicts the current organizational set-up of the Grantee:



                                                     City Manager




                      Executive Office of                                    Executive Office of
                                                    Various Other
                    Neighborhood Services -                                Economic Development -
                                                    Departments
                    Assistant City Manager                                Chief Development Officer



                         Director of
                                                                     Economic                 Various Other
                        Neighborhood
                                                                    Development               Departments
                          Services




                                                 Grants               Office
        Housing         Public Services
                                              Administration        Management




For a detailed delineation of the EONS and EOED staff, see Appendix B.

The Grantee provided CDBG funds to various City departments and to approximately 40
subrecipients to carryout eligible CDBG activities and provide services to the community. HUD
awards CDBG funds each Program Year. A Program Year is defined as a twelve-month period
beginning on the first calendar day of a month established by the jurisdiction. During Program
Years 25 and 26, the Grantee was awarded the following CDBG funds:

      Grant Program            Program Year             Program Fiscal Year             Grant Award
     B-99-MC-25-0026                25                   07/01/99-06/30/00              $5,754,000
     B-00-MC-25-0026                26                   07/01/00-06/30/01              $5,737,000

In addition to the grants awarded, the CDBG Program can generate Program Income. Because
grantees do not have to expend the funds in a single year, CDBG grant awards may be carried
forward from one year to the next. The Grantee expended a total of $6,117,701 during Program
Year 25 and $6,307,300 during Program Year 26, as of June 30, 2001. The use of all CDBG
grant funds is approved by the Grantee’s City Council. The following table displays the types of
activities funded through the CDBG Program and the amount expended during Program Years 25
and 26:




2002-BO-1001                                   Page 2
                                                                                    Introduction



                                                                       Funds Expended
Program                                                       Program Year 25 Program Year 26
Public/Human Services                                                 $763,583          $835,746
Affordable Housing                                                  $2,036,831        $1,845,304
Economic Development                                                  $495,559          $540,473
Parks                                                                $ 699,271          $552,911
Neighborhood Revitalization Fund                                      $665,898          $710,592
Webster Square Fire Station                                           $142,502          $434,221
Demolition                                                             $22,869          $142,350
Urban Renewal/Worcester Redevelopment Authority                       $197,931           $28,712
Public Facilities                                                           $0           $75,000
South Worcester Industrial Park                                             $0           $44,337
Northern Gateway                                                            $0           $10,750
Planning and Administrative Costs                                   $1,093,257        $1,086,904
                                              Total                 $6,117,701        $6,307,300




                                      The overall objective of our audit was to determine whether
Audit Objectives
                                      the reorganization was effective and allowed the Grantee to
                                      fulfill its CDBG Program responsibilities. Specific audit
                                      objectives included determining that the Grantee:

                                      Ø Carried out its CDBG activities in an economical,
                                        efficient and effective manner;

                                      Ø Complied with the CDBG Program requirements, laws
                                        and regulations; and

                                      Ø Maintained adequate controls to ensure compliance
                                        with HUD regulations.

                                      The audit was conducted between March 2001 and
Audit Scope and                       September 2001, and covered the period July 1, 1999
Methodology                           through June 30, 2001. The audit period was extended,
                                      where necessary, to meet our audit objectives.

                                      To accomplish the audit objectives, we performed the
                                      following:

                                      Ø Reviewed Federal requirements, including Code of
                                        Federal Regulations, OMB Circulars, and HUD
                                        Handbooks.

                                      Ø Reviewed files maintained by the HUD Massachusetts
                                        State Office, Office of Community Planning and

                                           Page 3                                   2002-BO-1001
Introduction


                  Development (CPD) relating to the Grantee’s CDBG
                  Program.

               Ø Reviewed Audited Financial Statements of the Grantee,
                 both the City's general purpose statements and those
                 required by OMB Circular A-133, for the periods ended
                 June 30, 1999 and June 30, 2000.

               Ø Reviewed the Grantee’s system of internal controls by
                 completing an internal control questionnaire,
                 observation, and testing of transactions.

               Ø Reviewed the Grantee’s former and present
                 organization and administrative structure to determine
                 the extent of any change in the total number of job
                 positions applicable to the CDBG Program, and to
                 assess the effect of these changes on the Grantee’s
                 ability to carry out its CDBG Programs.

               Ø Interviewed Grantee employees in key management and
                 staff positions within the EONS, the EOED, and the
                 Finance (Budget) Office to ensure that the
                 reorganization of the Grantee's OPCD was effective and
                 allowed the Grantee to fulfill its CDBG Program
                 responsibilities.

               Ø Identified the Programs being administered by the
                 Grantee with CDBG funds during Program Years 25
                 and 26, and selected three Programs for limited review
                 to ensure compliance with HUD regulations: 1)
                 Public/Human Services, 2) Affordable Housing and 3)
                 Economic Development. Our selection was based on
                 the total dollars per Program and we selected three of
                 the largest Programs.

               Ø From the three Programs selected, we examined the
                 three highest funded CDBG related activities within
                 each Program, and performed a limited review to
                 determine if those activities were in compliance with
                 HUD regulations and whether those activities met at
                 least one of the three CDBG national objectives. The
                 activities reviewed were:




2002-BO-1001       Page 4
                                                       Introduction


                  Affordable      Public/Human               Economic
Program
                   Housing          Services                Development
             1.    Worcester
                                 1.   Friendly House   1.     Black
                   Housing
                                 2.   South                   Fighting Back
Activities         Improvement
                                      Worcester               with Intellect
Reviewed           Program
                                      Neighborhood     2.     Centro Las
             2.    Lead Paint
                                      Center                  Americas
                   Program
                                 3.   Henry Lee        3.     Economic
             3.    Code
                                      Willis                  Development
                   Enforcement
                                      Community               Program
                   Program
                                      Center


  Ø Determined whether Grantee procedures are in
    place to adequately monitor subrecipient activities.

  Ø Determined whether the Grantee exceeded the 20
    percent limitation on CDBG Planning and
    Administrative Costs during Program Years 24, 25
    and 26.

  Ø Interviewed Grantee management and staff to
    determine the basis for the support and related costs
    allocated directly to the CDBG Program through the
    Worcester Housing Improvement Program (WHIP)
    and the Economic Development (ED) Program.

  Ø Reviewed the Grantee’s weekly summary time
    reports for the period July 24, 1999 to June 30,
    2001, and Expenditure Transaction Reports for
    Program Years 25 and 26 to determine whether
    salary and related costs allocated directly to the
    CDBG Program through the WHIP and the ED
    Program were supported and eligible.

  Ø Interviewed the Grantee’s staff and the staff from
    CPD, as necessary.




   Page 5                                              2002-BO-1001
Introduction




2002-BO-1001   Page 6
                                                                                         Finding 1


  Costs Improperly Allocated to the Community
       Development Block Grant Program
The City of Worcester (Grantee) allocated salaries, ($710,031) related fringe benefits ($113,570)
and ordinary maintenance ($77,746) for a total of $901,347 as direct costs to the Community
Development Block Grant (CDBG) Program when the costs were either unsupported or
ineligible. The Grantee used an unsupported allocation method that, according to key personnel,
was based on the available funding resources rather than the actual time spent on each Program
contrary to Federal regulations. As a result, there has been a reduction of funds for eligible
CDBG activities including benefits to low- and moderate-income individuals.



                                     Title 24, Code of Federal Regulations (CFR), Section
 Costs Must be Necessary,            570.200(a)(5) prescribes that costs incurred, whether
 Reasonable and                      charged on a direct or an indirect basis, must be in
 Adequately Documented               conformance with OMB Circular A-87. OMB Circular A-
                                     87, Attachment A, Section (C)(1) stipulates that eligible
                                     costs must be necessary and reasonable for the proper and
                                     efficient performance and administration of Federal awards,
                                     and eligible costs must be adequately documented.

                                     OMB Circular A-87, Attachment B, Sections (11)(h)(4) and
                                     (11)(h)(5) stipulate that:

                                          . . . where employees work on multiple activities or cost
                                         objectives, a distribution of their salaries or wages will
                                         be supported by personnel activity reports or equivalent
                                         documentation. Personnel activity reports or their
                                         equivalent must: (1) reflect an after-the-fact distribution
                                         of the actual activity for each employee and (2) be
                                         prepared at least monthly and signed by each employee.
                                         Budget estimates or other distribution percentages
                                         determined before the services are performed do not
                                         qualify as adequate supporting documentation.




                                         Page 7                                       2002-BO-1001
Finding 1


                           The Grantee expended $901,347 in unsupported and
  Total Unsupported and    ineligible costs from two of its CDBG-funded Programs
  Ineligible Costs         (Worcester Housing Improvement Program (WHIP) and
                           Economic Development (ED) Program) for Program Years
                           25 and 26, as follows:

                            Description                Unsupported    Ineligible     Total
                            Salaries                   $424,073      $285,958      $710,031
                            Fringe Benefits              68,142         45,428      113,570
                            Ordinary Maintenance         77,746               0      77,746
                            Total                      $569,961      $331,386      $901,347

                           The Grantee does not require personnel who work on
 Allocation Not Properly   multiple activities to prepare activity reports that reflect
 Supported                 actual work performed and does not maintain the necessary
                           documentation to support the cost of salaries, related fringe
                           benefits and ordinary maintenance allocated directly to the
                           CDBG Program. The Assistant City Manager stated that
                           the Grantee did not have a formal payroll allocation, but
                           instead required personnel to submit weekly time sheets
                           reflecting the actual time worked on each Program.

                           Interviews with Grantee personnel contradicted the
                           Assistant City Manager. According to Grantee personnel,
                           the Finance Department requested the staff to track their
                           time for a short period of time. They advised that the
                           Finance Department then generated an allocation for each
                           staff member identifying the number of hours to charge
                           each week per Program. Grantee personnel advised that
                           this allocation was not reflective of their actual time and
                           they were unsure how the Finance Department determined
                           the allocation. The Director of the Executive Office of
                           Neighborhood Services (EONS), which administers the
                           Grantee’s CDBG Program, also confirmed that a formal
                           payroll allocation existed. He advised that the former
                           Financial Management Coordinator developed the
                           allocation, but he was unsure of the basis for the allocation.

                           The former Financial Management Coordinator advised
                           that personnel costs were allocated based on the available
                           revenue sources. He advised that he knew which Program
                           or Programs each staff person worked on, and he allocated
                           their costs accordingly. For instance, if a staff member
                           worked 100 percent of the time on a specific Program, the
                           related costs would be allocated 100 percent to that
                           particular Program. He further stated that the indirect costs

2002-BO-1001                   Page 8
                                                                                Finding 1


                              used the same allocation formula. He provided no
                              explanation on how he knew which staff were working 100
                              percent of their time on a specific Program or any portion
                              therein. He acknowledged that no documentation was
                              available to support the allocation because it was based on
                              the revenue available. Our review of the weekly summary
                              payroll sheets from July 24, 1999 through June 30, 2001
                              revealed little change to the Grantee’s overall payroll
                              allocation since August 1999.

                              Using the Grantee’s weekly summary payroll sheets, we
$424,073 in Unsupported       determined that the Grantee charged $424,073 in
Salaries                      unsupported salaries to the WHIP and the ED Program.
                              The Grantee could not correlate the hours charged to the
                              WHIP and the ED Program to the output produced by their
                              personnel. Although we believe that some of these hours
                              may legitimately be direct costs, the Grantee did not
                              provide a basis to adequately support its allocation. The
                              Grantee charged the following salaries:

                                                     Total Salaries
                                              Program Year 25 Program Year 26      Total
                               Housing
                                                  $176,075         $109,138       $285,213
                               Department
                               Economic
                               Development        $62,950          $75,910        $138,860
                               Department
                               Total
                               Unsupported        $239,025         $185,048       $424,073
                               Salaries

                              The Housing Department administers the WHIP and the
                              Economic Development Department administers the ED
                              Program.

                              Grantee personnel stated that they worked fewer hours on
  Allocation not Reflective   the WHIP than were actually allocated to the Program. We
 of Actual Costs              interviewed the four current employees allocated to the
                              WHIP. The first individual stated that he spent minimal
                              time working on the Program. The second stated that
                              approximately five percent of his time was related to the
                              WHIP, and the third stated that she basically provides
                              technical assistance on the WHIP such as fielding phone
                              calls from local residents regarding housing issues. The
                              fourth, the current Housing Coordinator, stated that he
                              works one hour per week on the WHIP. Our review of the
                              Housing Department time sheets disclosed that, during

                                  Page 9                                      2002-BO-1001
Finding 1


               Program Years 25 and 26, all four of these personnel are
               allocated to the WHIP for 70 to 75 percent of their time.
               The former Director of the Housing Department also
               allocated 70 to 75 percent of his time to the WHIP during
               Program Year 25. The current Housing Coordinator is
               unsure why his personnel are allocated mostly to the WHIP.
               He speculated that, if the Housing Department's salaries
               were allocated to CDBG Planning and Administrative
               Costs instead of the WHIP, the Grantee may exceed the 20
               percent cap imposed on Planning and Administrative Costs.

               ED personnel believe that their salary allocation is accurate;
               however, our analysis shows that: (1) the Grantee is
               allocating salaries to a Program where it is not expending
               appropriated funds and (2) the allocation changed for
               certain personnel. As of June 30, 2001, the Grantee
               appropriated $157,700 and $198,619 to its ED
               Environmental Remediation funds and ED Loan Pool,
               respectively for Program Years 24, 25, and 26. As of June
               30, 2001, the Grantee had expended $2,200 from the ED
               Environmental Remediation fund and no funds from the
               ED Loan Pool. As a result, we believe the salaries
               allocated directly to the ED Program are excessive.
               Additionally our review of the ED time sheets showed that
               personnel used two different percentages to allocate their
               time during Program Year 25. For the first nine months of
               Program Year 25, three personnel allocated 20 to 45
               percent of their time directly to the ED Program. For the
               last three months, these three personnel allocated 80 to 90
               percent of their time directly to the ED Program each week.
               During Program Year 26, the four personnel who allocated
               time to the ED Program allocated 60 to 90 percent of their
               time directly to the ED Program each week.




2002-BO-1001       Page 10
                                                                              Finding 1


                           In addition to the Grantee’s unsupported allocation, our
Responsibilities are not   review of the tasks performed by the Housing and ED
Programmatic               Department personnel disclosed that their duties were
                           generally administrative in nature. Duties included:

                           Ø Providing information to citizens;

                           Ø Developing interagency agreements and agreements
                             with subrecipients and contractors to carry out Program
                             activities;

                           Ø Monitoring Program activities for progress and
                             compliance with Program requirements; and

                           Ø Preparing reports and other documents related to the
                             Program for submission to HUD.

                           While some of the tasks performed by the Housing and ED
                           personnel may be eligible, we cannot determine what
                           percentage of their time is administrative and what
                           percentage is direct. Therefore, we consider the $424,073
                           for salaries to be unsupported. The Director of the EONS
                           agreed that it appeared too many hours were being allocated
                           to the WHIP and welcomed our assessment so that
                           corrections could be made.

                           OMB Circular A-87, Attachment A, Section (C)(1)
Regulations Define         stipulates, that to be eligible under Federal awards, costs
Allowable Direct and       must be necessary and reasonable for the proper and
Administrative Costs       efficient performance and administration of Federal awards
                           and costs must also be adequately documented.
                           Attachment A, Section (E) of the circular defines direct
                           costs as those that can be identified specifically with a
                           particular final cost objective. Employee compensation is
                           chargeable to Federal awards as a direct cost only to the
                           extent of the time devoted and identified specifically to the
                           performance of those awards.

                           Title 24 CFR Section 570.206(a)(1) states that salaries,
                           wages and related costs of the CDBG recipients’ staff, the
                           staff of local public agencies, or other staff engaged in
                           program administration may be charged as Planning and
                           Administrative Costs to the CDBG Program. This includes
                           reasonable costs of overall program management,
                           oversight, coordination, monitoring and evaluation of the

                               Page 11                                     2002-BO-1001
Finding 1


                              CDBG Program. Program administration includes the
                              following types of assignments:

                              (i)        Providing local officials and citizens with
                                         information about the CDBG Program;

                              (ii)       Preparing program budgets and schedules, and
                                         amendments thereto;

                              (iii)      Developing systems for assuring compliance with
                                         program requirements;

                              (iv)       Developing interagency assignments and
                                         agreements with subrecipients and contractors to
                                         carry out program activities;

                              (v)        Monitoring program activities for progress and
                                         compliance with program requirements;

                              (vi)       Preparing reports and other documents related to the
                                         program for submission to HUD;

                              (vii)      Coordinating the resolution of audit and monitoring
                                         findings;

                              (viii) Evaluating program results against stated
                                     objectives; and

                              (ix)       Managing or supervising persons whose primary
                                         responsibilities with regard to the program include
                                         such assignments as those described in (i) to (viii)
                                         above.

                              Although the Housing and ED Departments are responsible
 Several Grantee              for administering the Grantee’s WHIP and ED Program,
 Departments Allocate Costs   our review disclosed that several other Grantee
 Directly to the WHIP and     Departments were charging a portion of their salaries as
 the ED Program               direct costs to the WHIP and the ED Program as well.
                              These Departments included City Management, Finance
                              (Budget) Office, Office Management and Public Service
                              Department. The duties performed by these other Grantee
                              Departments did not provide a direct benefit to the WHIP
                              and the ED Program. Therefore, the costs should have
                              been allocated to the Grantee’s CDBG Planning and
                              Administrative Costs or another City, State or Federal

2002-BO-1001                          Page 12
                                                                               Finding 1


                            Program, as applicable. The Grantee has job descriptions
                            to differentiate pay grades, but these did not identify
                            specific duties and responsibilities.

                            Based on the Grantee’s weekly summary payroll sheets
$285,958 in Ineligible      from July 24, 1999 to June 30, 2001, we determined that
Salaries                    these other Departments charged $285,958 in ineligible
                            salaries to the WHIP and the ED Program, as follows:

                                                     Program      Program
                                                     Year 25      Year 26       Total
                                    WHIP              $108,775     $105,091    $213,866
                                      ED               $46,943      $25,149     $72,092
                                Total Ineligible
                                   Salaries            $155,718     $130,240   $285,958

                            The questioned costs are in either managerial or
                            administrative support positions that, by their very nature,
                            do not ordinarily provide direct services to any one
                            particular program, but instead to a number of programs
                            and initiatives.

                            In addition to the regular salaries allocated directly to the
Questionable Fringe         Grantee’s WHIP and ED Program, the fringe benefits
Benefit Costs of $113,570   directly related to those salaries were also allocated.
                            According to the Grantee’s Expenditure Transaction
                            Analysis Reports provided for the WHIP and the ED
                            Program, fringe benefits including health insurance and
                            retirement funds were allocated to the WHIP and the ED
                            Program during Program Years 25 and 26. As the fringe
                            benefits charged to the WHIP and the ED Program were in
                            direct relation to the Grantee’s salaries, which we
                            determined to be unsupported or ineligible, the associated
                            fringe benefits are also considered unsupported or
                            ineligible. We determined that 60 percent of the total
                            allocated salaries were unsupported and the remaining 40
                            percent were ineligible. Therefore, we consider 60 percent
                            of the fringe benefits to be unsupported and the remaining
                            40 percent to be ineligible.




                                Page 13                                     2002-BO-1001
Finding 1


                          The table displays the total fringe benefits allocated to the
                          WHIP and the ED Program during Program Years 25 and 26,
                          and the amounts considered unsupported and ineligible:

                                                Total      Unsupported      Ineligible
                          Program              Charged       (60%)           (40%)
                          WHIP                $ 80,458      $48,275         $32,183
                          ED                     33,112      19,867          13,245
                          Total               $113,570      $68,142         $45,428

                          The Grantee also allocated ordinary maintenance costs to the
 Ordinary Maintenance     WHIP during Program Years 25 and 26 without adequate
 Costs of $77,746         support for its allocation. No ordinary maintenance costs
 Questionable             were allocated to the ED Program during this timeframe.
                          The ordinary maintenance costs consisted of leases,
                          equipment rentals, postage, and telephone charges.
                          According to the former Financial Management Coordinator,
                          the amount charged was based on the staff allocated to the
                          WHIP. Since the Grantee could not adequately support the
                          allocation of its staff to the WHIP, we also consider the
                          allocation of ordinary maintenance to be unsupported. The
                          Housing Department, which administers the WHIP, occupied
                          one floor of one of the Grantee’s buildings; however, the
                          Grantee expended $35,200 to cover lease payments for four
                          floors of this building for a four-month period during
                          Program Year 25 and another four-month period during
                          Program Year 26. Grantee staff from other Departments
                          occupied the other three floors.       The total ordinary
                          maintenance expended from the WHIP during Program
                          Years 25 and 26 is:

                                        Program     Program            Total
                           Program      Year 25     Year 26       Unsupported Costs
                            WHIP        $39,363     $38,383           $77,746

                          Title 24 CFR Section 570.200(g) states that Planning and
Administrative Costs      Administrative Costs cannot exceed 20 percent of the sum
Limited to 20% of Grant   of the CDBG entitlement grant awarded for that Program
                          Year plus Program Income received by the recipient and its
                          subrecipients during that Program Year. Proper allocation
                          of costs currently charged to the WHIP or the ED Program
                          for Program Years 25 and 26 could result in the Grantee
                          exceeding the statutory 20 percent limitation. During
                          Program Year 25, the Grantee spent 18.7 percent for CDBG
                          Planning and Administrative Costs. During Program Year


2002-BO-1001                  Page 14
                                                                                       Finding 1


                                 26, the Grantee also spent 18.7 percent for CDBG Planning
                                 and Administrative Costs prior to any adjustment.

                                                           Program      Program
                                     Category                                          Totals
                                                            Year 25     Year 26
                            CDBG Grant                     $5,754,000   $5,737,000   $11,491,000
                            Program Income Generated         $103,467      $60,367      $163,834
                            Subtotal                       $5,857,467   $5,797,367   $11,654,834
                            20 percent of the Subtotal     $1,171,493   $1,159,473    $2,330,967
                            Planning and Administrative
                                                           $1,093,257   $1,086,904    $2,180,161
                            Costs
                            Planning & Admin. Costs as
                                                               18.7%        18.7%         18.7%
                            a percentage of the subtotal

                                 The Grantee will be required to use non-Federal funds to
                                 reimburse the CDBG Program for any amount exceeding
                                 the 20 percent cap.

                                 As of the beginning of Program Year 27 (July 1, 2001), the
Grantee Willing to Update        Grantee implemented a new administrative allocation that
Allocation                       reduces the costs allocated to the WHIP and the ED Program.
                                 The allocation has since been updated—further reducing the
                                 costs allocated to the WHIP and the ED Program. The
                                 newest allocation has been sent to the Grantee’s City
                                 Manager for his review and approval. Although the
                                 proposed allocation submitted to the City Manager attempts
                                 to correct the situation, the Grantee still does not have a valid
                                 basis for its allocation. The allocation implemented is still
                                 based on the Grantee’s available budget rather than the actual
                                 work performed by the Grantee’s employees as required by
                                 OMB Circular A-87, Attachment B, Section (11)(h)(4) and
                                 (11)(h)(5). As a result, the Grantee may still be improperly
                                 allocating its salaries and related expenses.

                                 The Grantee’s Assistant City Manager agreed that the old
                                 allocation to the WHIP and the ED Program required
                                 correction. He also stated that the Grantee would like to
                                 discuss a work plan with HUD Massachusetts State Office,
                                 Office of Community Planning and Development (CPD) to
                                 correct the issue within an agreed upon timeframe. The
                                 Director of EONS also expressed the desire to take our
                                 recommendations and revise the current allocation. The
                                 Grantee disagrees with our monetary analysis and is awaiting
                                 a decision from CPD. Once that determination is made, the
                                 Grantee intends to prepare a more thorough analysis and
                                 update their allocation accordingly.


                                      Page 15                                        2002-BO-1001
Finding 1



Auditee Comments   The Grantee disagreed that costs were improperly allocated
                   to its CDBG Program. The Grantee contends that we did
                   not consider the full scope of the Programs that the Grantee
                   conducted using CDBG funds. The Grantee believes its
                   activities and outcomes during this time period
                   demonstrated that it upheld the letter and intent of the
                   national objectives of the CDBG Program.

                   The Grantee used the Annual Assessment Reports prepared
                   by CPD as a source of guidance and management direction
                   in the administration of the Grantee's CDBG Program.
                   These reports cited the Grantee for administrative
                   excellence and outstanding leveraging of other resources.

                   In support of these contentions, the Grantee provided
                   performance based activity reports for the period July 1999
                   to June 2000. The Grantee advised that the City Manager
                   initiated a Performance Based Management System
                   whereby each Department developed written projected
                   performance goals and objectives for the twelve-month
                   fiscal year. The Grantee provided numerous spreadsheets
                   detailing performance based budgets and housing
                   performance goals.

                   The Grantee did not implement performance based
                   reporting during its Program Year 26 and stated that the
                   Year 26 documentation is admittedly lacking due to
                   changes in high-level administrative personnel during this
                   period. The Grantee did provide, however, a schedule of
                   Economic Development Staff Responsibilities as of
                   January 16, 2001 to support their contention that Grantee
                   personnel performed direct services during Program Year
                   26. The Grantee advised they pro-rated time to arrive at a
                   twelve-month average.      The Grantee also provided
                   examples of other performance based budget activity
                   reports for its Management and Support Staff for periods
                   prior to our audit period.

                   The Grantee stated that:

                   Time sheets in addition to documented field reports are
                   currently being maintained by staff personnel to determine
                   administrative and direct service activities provided by the

2002-BO-1001           Page 16
                                                                         Finding 1


                    staff. These time sheets and documented field reports are
                    submitted to program directors for review and approval.
                    Both the time sheet and the field reports are forwarded to the
                    Assistant Grantee Manager for approval. The time sheets
                    will be forwarded to the budget office with the intention of
                    allocating employees time towards the appropriate funding
                    sources. All Grantee department's financed under the Block
                    Grants will be required to follow this same process in the
                    future.

                    The Grantee believes that the costs cited will be deemed
                    supported and eligible and, if required, an amended
                    reallocation process will show that administrative and
                    direct service allocations were properly expended.

                    Due to its voluminous content, the Grantee’s entire
                    response was forwarded to CPD under a separate letter.
                    We included the narrative to the Grantee’s response in
                    Appendix C.

OIG Evaluation of
                    Our review determined that the Grantee lacked an approved
Auditee Comments    allocation compliant with OMB Circular A-87 Cost
                    Principles for State and Local Governments that reflects
                    actual hours worked on each program signed by each
                    employee. In interviews, the Grantee acknowledged its lack
                    of an approved plan. Without an approved allocation plan,
                    all salaries, related fringe benefits and any overhead costs
                    using the same methodology are questionable. We also
                    reached our conclusion based upon existing HUD regulations
                    and Federal Cost Principles coupled with an analysis of
                    employee time allocation sheets, interviews with employees,
                    and discussions with Grantee management.

                    The Grantee contends that our conclusions were based on a
                    limited understanding of its overall revitalization strategy, as
                    well as the level of staff involvement on those activities. The
                    Grantee also believes that the interviews we conducted,
                    along with our review of the employee time allocation sheets
                    for the audit period, formed the basis of our conclusions.
                    Our understanding of the Grantee’s overall revitalization
                    strategy and level of staff involvement was limited only to
                    the extent in which the Grantee provided information and
                    documentation to support its revitalization strategy and level


                        Page 17                                       2002-BO-1001
Finding 1


               of staff involvement. The Grantee’s revitalization strategy is
               not relevant to our conclusions.

               Although the Grantee provided additional documentation for
               our review and consideration, this documentation was
               limited generally to the Grantee's Program Year 25,
               contained some data input errors, and did not correlate the
               performance based reports and the allocation in place during
               the audit period. The Grantee provided some aspect of direct
               services through its WHIP and ED Program, but was unable
               to produce a valid basis for the allocation of salaries. The
               Grantee’s allocation was based on the available funding
               resources, rather than the actual time spent by its employees
               on each Program, which is contrary to Federal Cost
               Principles.

               The Grantee also referred to the HUD Annual CDBG
               Assessments for the Grantee’s Program Years 23, 24, and 25.
               With the exception of Program Year 25, these Assessments
               covered years prior to our audit period. The Assessments
               covering the Grantee's Program Years 23 and 24 recognized
               the Grantee for administrative excellence and its leveraging
               capacity. The Assessments provided do not constitute
               monitoring reports and are not meant to be a comprehensive
               evaluation of specific programs. Further, the Assessment for
               Program Year 24 cited a concern with the overall decrease in
               the level of housing productivity while, at the same time, the
               number of staff assigned increased. The Assessment stated
               that, based on conversations with the Grantee staff, personnel
               worked on other projects including demolition and tax title
               properties that may have contributed to a decrease in
               productivity. More importantly, the Assessment stated,

                  The employee's time is not being charged appropriately.
                   A review should be conducted in order to determine if
                   the program staff is charging their time to the
                   appropriate categories.

               Our review concluded that the Grantee's employees were, in
               fact, charging their time incorrectly as direct service costs
               to the WHIP and the ED Program.




2002-BO-1001       Page 18
                                                                       Finding 1




Recommendations   We recommend that you:

                  1A.      Instruct the Grantee to establish, and submit for HUD
                           approval, an appropriate method for allocating direct
                           and indirect costs to the WHIP and the ED Program,
                           in accordance with Federal Cost Principles, for
                           implementation retroactive to July 1, 2001, and for
                           use subsequent to Program Year 26.

                  1B.      Instruct the Grantee to provide sufficient
                           documentation to support the $569,961 ($424,073 –
                           Salaries; $68,142 – Fringe; and $77,746 – Ordinary
                           Maintenance) in unsupported costs; or reimburse the
                           CDBG Program from non-Federal funds accordingly.
                           As the questioned costs relate to the number of hours
                           specific individuals allocated to the Grantee’s WHIP
                           and ED Program, the supporting documentation
                           should clearly identify the number of hours attributed
                           to each specific individual and the methodology used
                           to determine those hours.

                  1C.      Require the Grantee to reimburse the ineligible costs
                           of $331,386 to the CDBG Program from non-Federal
                           funds ($285,958 – Salaries and $45,428 – Fringe) or
                           provide documentation to support the reallocation of
                           those costs to Planning and Administrative Costs.

                  1D.      Require the Grantee to use non-Federal funds to
                           reimburse the CDBG Program any amount in excess
                           of the 20 percent statutory limitation on CDBG
                           Planning and Administrative Costs.             This
                           reimbursement should include any excess costs
                           identified after proper allocation of the
                           administrative costs currently charged to the WHIP
                           and the ED Program.




                        Page 19                                    2002-BO-1001
Finding 1




2002-BO-1001   Page 20
Management Controls
In planning and performing our audit, we obtained an understanding of the management controls
that were relevant to our audit objectives. We considered the management control systems of the
City of Worcester (Grantee), specifically as they related to the Community Development Block
Grant (CDBG) Program in order to determine our audit procedures and not to provide assurance
on management controls.

Management controls consist of a plan, organization, methods, and/or procedures adopted by
management to ensure 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.


                                    We determined the following management controls were
 Relevant Management                relevant to our audit objectives:
 Controls
                                    Ø Controls over the administration of the CDBG Program;

                                    Ø Controls over program receipts and disbursements to
                                      ensure that costs charged were eligible, reasonable, and
                                      met at least one national objective;

                                    Ø Controls to ensure adequate documentation supporting
                                      program expenditures was maintained;

                                    Ø Controls to ensure that the Grantee was adequately
                                      monitoring subrecipient activities; and

                                    Ø Controls over monitoring overall program performance.

                                    A significant weakness exists 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.

                                    Our review identified a significant weakness in the
  Significant Weaknesses            allocation method used by the Grantee for the costs of
                                    salaries, related fringe benefits, and ordinary maintenance
                                    costs. The Grantee lacked the necessary controls to ensure
                                    that these costs were properly allocated to the CDBG
                                    Program for those employees who worked on multiple
                                    programs. These weaknesses are discussed in the finding
                                    section of this report.
                                        Page 21                                     2001-BO-1002
Management Controls




2002-BO-1001          Page 22
                                                                                  Appendix A

Ineligible and Unsupported Costs



                                                                Ineligible      Unsupported
Finding 1                                                       Costs 1/         Costs 2/
Salaries, fringe and ordinary maintenance costs allocated
directly to the CDBG Program without adequate
documentation                                                                    $569,961
Salaries and fringe benefits allocated directly to the CDBG
Program, when they were ineligible as direct costs to the
CDBG Program                                                    $331,386




     1/ Ineligible costs are those costs that are questioned because of an alleged violation of
        a provision of a law, regulation, contract, grant, cooperative agreement, or other
        agreement or document governing the expenditure of funds.

     2/    Unsupported costs are those costs whose eligibility cannot be clearly determined
          during the audit since such costs were not supported by adequate documentation.




                                       Page 23                                    2002-BO-1001
Appendix A




2002-BO-1001   Page 24
                                                                                               Appendix B

Post-Reorganization Charts

                                EXECUTIVE OFFICE OF NEIGHBORHOOD SERVICES


                                                Assistant City Manager -
                                                Neighborhood Services/
                                                   Legislative Affairs


                                                       Director -
                                                 Neighborhood Services


          Housing                    Public Services            Grants Administration   Office Management


      Coordinator of                 Coordinator of              Associate Planner        Administrative
        Housing                      Public Services                                        Assistant


Principal Staff Assistant (2)    Principal Staff Assistant        Staff Assistant III   Principal Clerk (2)


   Staff Assistant III (3)        Senior Staff Assistant           Principal Clerk         Clerk/Typist


                                    Staff Assistant III


                                     Staff Assistant I


                                     Staff Assistant




Note: (2) or (3) is the number of positions for each title




                                                    Page 25                                    2002-BO-1001
Appendix B



                          EXECUTIVE OFFICE OF ECONOMIC DEVELOPMENT

                                                             Chief Development
                                                                   Officer




                           Regulatory
                        Services Division                                                              Worcester
                              Code                                                                   Redevelopment
                          Enforcement                                                                Authority Board



    Code &                                                                                             Director of
    Zoning                                                                                              Project
  Enforcement                           Board &                                                       Management
                                                                             Office Management
                                     Commissions
                                                                                Administrative           Project
                                        Services
                                                                                  Assistant             Engineer
                                     Principal Staff
                                                                                Principal Staff
                                  Staff Assistant II (3)
                                                                                  Assistant             Principal
                                                                             Staff Assistant I (2)       Clerk


                                                                                   Cultural
                                                       Economic                                      Chief Staff
         Planning                 Marketing                                      Development
                                                      Development                                    Assistant
                                                                                   Officer

                                                       Director of
      Coordinator of              Marketing                                        Cultural
                                                       Economic                                       BVHCC
        Planning                   Director                                      Development
                                                      Development

      Client Server
                                                        Chief Staff
      Programmer/
                                                        Assistant
         Analyst

                                                      Principal Staff
      Principal Staff
                                                        Assistant

     Staff Assistant                                   Senior Staff
            III                                         Assistant
     Staff Assistant                                  Staff Assistant
          II (3)                                             III
                                                      Staff Assistant
                                                             I


Note: (2) or (3) is the number of positions for each title



2002-BO-1001                                         Page 26
                              Appendix C

Auditee Comments




                   Page 27   2002-BO-XXXX
Appendix C




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          Appendix C




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Appendix C




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          Appendix C




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Appendix C




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          Appendix C




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Appendix C




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          Appendix C




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Appendix C




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          Appendix C




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Appendix C




2002-BO-1001   Page 38
          Appendix C




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Appendix C




2002-BO-1001   Page 40
                                                                               Appendix D

Distribution
Inspector General, G
Deputy Assistant Inspector General for Audit, GA
Assistant Inspector General for Audit, GA
Assistant Inspector General for Investigation, GI
Acting Director, Program Research and Planning Division, GAP
Director, Information Systems Audit Division, GAA
Counsel to the Inspector General, GC
Central Records, GF
Semi-Annual Report Coordinator, GF
Assistant Inspector General, Office of Management & Policy, GF
Director of Internal Affairs, GF
Secretary, S
Deputy Secretary, S
Chief of Staff, S
Deputy Chief of Staff for Policy & Programs, S
Deputy Chief of Staff for Intergovernmental Affairs, S
Senior Advisor to Deputy Secretary, S
Assistant to the Secretary for White House Liaison, F
Press Secretary/Senior Communications Advisor to the Secretary, W
Chief Executive Officer for Administrative Operations and Management, S
Assistant Deputy Secretary for Field Policy and Management, SFD
Chief Information Officer, Q
Chief Financial Officer, F
General Counsel, C
Special Counsel, C
Ronald A. Rosenfield, President, Ginnie Mae, T
Assistant Secretary for Congressional and Intergovernmental Relations, J.
Assistant Secretary for Housing/Federal Housing Commissioner, H
Assistant Secretary for Community Planning and Development, 1AHMLAP
Assistant Secretary for Public and Indian Housing, P
Deputy Director, Center for Faith-Based and Community Initiatives, AK
Director, Office of Departmental Equal Employment Opportunity, U
Director, Office of Departmental Operations and Coordination, I
Director, Office of Federal Housing Enterprise Oversight, L
Director, Office of Healthy Homes and Lead Hazard Control, L
General Deputy Assistant Secretary for Policy Development and Research, H
General Deputy Assistant Secretary for Fair Housing and Equal Opportunity, E
General Deputy Assistant Secretary for Administration, AA
Special Agent-In-Charge, 1AGI
Primary Field Audit Liaison Officer, 3AFI
Departmental Audit Liaison Officer, FMA
Auditee
Acquisitions Librarian, Library, AS
District Inspector General (2-11)

                                        Page 41                                2002-BO-1001
Appendix D


Regional Directors
Stanely Czerwinski, Associate Director, Resources, Community, and Economic Development
Division, United States General Accounting Office, 441 G Street, NW, Room 2723, Washington,
DC 20548

Steve Redburn, Chief, Housing Brach, Office of Management & Budget, 725 17th Street, NW,
Room 9226, New Executive Office Building, Washington, DC 20503

The Honorable Fred Thompson, Ranking Member, Committee on Governmental Affairs, 340
Dirksen Senate Office Building, United States Senate, Washington, DC 20510

The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs, 706
Hart Senate Office Bldg., United States Senate, Washington, DC 20510

The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn Bldg.,
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

Andy Cochran, House Committee on Financial Services, 2129 Rayburn H.O.B., Washington, DC
20515

Clinton C. Jones, Senior Counsel, Committee on Financial Services, U.S. House of
Representatives, B303 Rayburn H.O.B., Washington, DC 20515




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