AUDIT REPORT
HOUSING AUTHORITY OF THE CITY OF ALTON
LOW-INCOME HOUSING AND PUBLIC HOUSING DRUG
ELIMINATION PROGRAMS
ALTON, ILLINOIS
2002-CH-1002
MARCH 29, 2002
OFFICE OF AUDIT, MIDWEST
CHICAGO, ILLINOIS
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Issue Date
March 29, 2002
Audit Case Number
2002-CH-1002
TO: Linford Coleman, Director of Public Housing Hub, Illinois State Office
FROM: Heath Wolfe, District Inspector General for Audit, Midwest
SUBJECT: Housing Authority Of The City Of Alton
Low-Income Housing And Public Housing Drug Elimination Programs
Alton, Illinois
We completed an audit of the Housing Authority of the City of Alton’s Low-Income Housing and
Public Housing Drug Elimination Programs. The audit resulted from citizen complaints to our
Office. The objectives of our audit were to determine whether the complainants’ allegations were
substantiated and whether HUD’s rules and regulations were followed. The complainants’ specific
allegations were: (1) the Authority’s former Executive Director was granting preferential treatment
to certain tenants; (2) improper use of HUD funds by the Authority; and (3) poor controls over the
Authority’s equipment.
We found no evidence that the Housing Authority’s former Executive Director was granting
preferential treatment to certain tenants. However, we found that the Housing Authority did not
follow HUD’s requirements, the Annual Contributions Contract, and its policies to ensure the
Authority’s Low-Income Housing and Public Housing Drug Elimination Programs were operated
efficiently and effectively. Specifically, the Authority: failed to make required tax payments
totaling $50,870; claimed at least $38,823 in excess operating subsidies over a four year period; did
not make sufficient efforts to collect tenant accounts receivable totaling $39,701; inappropriately
charged expenses of $144,767 to its Drug Elimination Grants; and improperly paid its former
Executive Director $6,635 for accrued but unused sick leave. We also found that the Housing
Authority’s system of management controls were weak. The Housing Authority’s controls did not
assure that it adhered to its policies concerning performance appraisals, inventory of equipment,
allocation of unit size, tenant grievances, rental collections and evictions, and travel
reimbursements to members of the Board of Commissioners and the Authority’s staff for
authorized travel. As a result, HUD lacks assurance that the Housing Authority’s resources were
used to the maximum extent to benefit low and moderate income tenants.
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Management Memorandum
Within 60 days, please provide us, for each recommendation made in this report, a status report on:
(1) the corrective action taken; (2) the proposed corrective action and the date to be completed; or
(3) why action is considered unnecessary. Also, please furnish us copies of any correspondence or
directives issued because of the audit.
Should you or your staff have any questions, please contact Ronald Huritz, Assistant District
Inspector General for Audit, at (312) 353-6236 extension 2675 or me at (312) 353-7832.
2002-CH-1002 Page ii
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Executive Summary
We completed an audit of the Housing Authority of the City of Alton’s Low-Income Housing and
Public Housing Drug Elimination Programs. The audit resulted from citizen complaints to our
Office. The objectives of our audit were to determine whether the complainants’ allegations were
substantiated and whether HUD’s rules and regulations were followed. The complainants’ specific
allegations were: the Authority’s former Executive Director was granting preferential treatment to
certain tenants; improper use of HUD funds by the Authority; and poor controls over the
Authority’s equipment.
We found no evidence that the Housing Authority’s former Executive Director was granting
preferential treatment to certain tenants. However, the Housing Authority did not follow HUD’s
requirements, the Annual Contributions Contract, and its policies to ensure the Authority’s Low-
Income Housing and Public Housing Drug Elimination Programs were operated efficiently and
effectively. Specifically, the Authority: failed to make required tax payments totaling $50,870;
claimed at least $38,823 in excess operating subsidies over a four year period; did not make
sufficient efforts to collect tenant accounts receivable totaling $39,701; improperly charged
expenses of $144,767 to its Drug Elimination Grants; and inappropriately paid its former Executive
Director $6,635 for accrued but unused sick leave.
We also found that the Housing Authority’s system of internal accounting and management
controls were weak. The Housing Authority’s controls did not assure that it adhered to the
Authority’s policies concerning performance appraisals, inventory of equipment, allocation of unit
size, tenant grievances, rental collections and evictions, and travel reimbursements to members of
the Board of Commissioners and the Authority’s staff for authorized travel.
The Housing Authority: did not make required tax payments
The Authority Must totaling $50,870; claimed at least $38,823 in excess
Resolve Significant operating subsidies over a four year period; did not make
Monetary Issues Totaling sufficient efforts to collect tenant accounts receivable totaling
$280,796 $39,701; inappropriately charged expenses of $144,767 to its
Drug Elimination Grants; and improperly paid its former
Executive Director $6,635 for accrued but unused sick leave.
As a result, HUD lacks assurance that the Housing
Authority’s resources were used to the maximum extent to
benefit low and moderate income tenants.
The Housing Authority’s system of internal accounting and
The Authority Needs To management controls were weak. Specifically, controls did
Strengthen Its Controls not assure that the Housing Authority adhered to its own
policies concerning performance appraisals, inventory of
equipment, allocation of unit size, tenant grievances, rental
collections and evictions, and travel reimbursements to
members of the Board of Commissioners and the Authority’s
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Executive Summary
staff for authorized travel. As a result, HUD’s and the
Housing Authority’s requirements were violated, and the
Authority’s operations were not conducted in an efficient and
effective manner.
We recommend that HUD’s Director of the Illinois State
Recommendations Office of Public Housing Hub assure that the Housing
Authority reimburses HUD for the ineligible use of funds
and implements controls to correct the weaknesses cited in
this report.
We presented our draft findings to the Housing Authority’s
Interim Executive Director and HUD’s staff during the audit.
We held an exit conference with the Authority on November
26, 2001. The Authority agreed to implement corrective
action to improve its controls over: Payments-In-Lieu-Of-
Taxes; operating subsidy requests; tenant rental collections;
payment of Drug Elimination expenses; performance
appraisals; allocation of unit size; equipment; and travel
expenses and authorizations. The Authority disagreed that
its former Executive Director was improperly paid for
unused sick leave.
We included paraphrased excerpts of the Housing
Authority’s comments with each finding. The complete text
of the comments is in Appendix B.
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Table Of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1 The Authority Must Resolve Significant Monetary Issues
Totaling $280,796 3
2 The Authority Needs To Strengthen Its Controls 15
Management Controls 23
Follow Up On Prior Audits 25
Appendices
A Schedule of Ineligible Costs 27
B Auditee Comments 29
C Distribution 33
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Introduction
The Housing Authority of the City of Alton was established under State of Illinois law. The
Housing Authority contracts with HUD to provide low and moderate-income persons with safe
and sanitary housing through rent subsidies. A five member Board of Commissioners governs
the Authority. The Chairperson of the Board is Mary Eckhouse. During our audit, the
Authority’s former Executive Director Stanley Henderson resigned effective June 5, 2001. The
Authority’s Interim Executive Director is Jeffrey W. Copley. The Authority’s books and records
are located at 2406 Crawford Street, Alton, Illinois.
As of February 2002, the Housing Authority operated three HUD-funded programs: (1) a Low-
Income Housing Program consisting of 329 units; (2) a Public Housing Drug Elimination Grant
Program; and (3) a Comprehensive Improvement Assistance Program. The Low-Income
Housing Program is designed to provide housing to low and moderate income individuals whose
annual income does not exceed 80 percent of the median income for the surrounding community.
HUD’s Drug Elimination Grant Program provides grants to public housing authorities to reduce
drug-related crime in and around public housing sites. The Comprehensive Improvement
Assistance Program funds capital improvements and related management improvements in
public housing developments to upgrade living conditions, correct physical conditions, and
achieve operating efficiency and economy.
The objectives of our audit were to determine whether the
Audit Objectives complainants’ allegations were substantiated and whether
HUD’s rules and regulations were followed.
We conducted the audit at HUD’s Illinois State Office and
Audit Scope And the Housing Authority’s office. We performed our on-site
Methodology audit work between February 2001 and September 2001.
To accomplish our audit objectives, we interviewed: HUD’s
staff; the Housing Authority’s former and current officials,
former and current staff, and the fee accountant, nine of the
Authority’s tenants; and the Mayor of the City of Alton.
We analyzed the following items: tenant files; cash
disbursements and invoices; vendor files; vacancy reports; all
of the Public Housing Drug Elimination Program Grant
vouchers for January 1, 1997 to March 31, 2001; Board
meeting minutes; payroll records and personnel files; Line of
Credit Control System reports; bank statements and canceled
checks; equipment records; cash receipts and registers; all of
the travel vouchers for travel outside of the Housing
Authority's jurisdiction (defined as the St. Louis
metropolitan area and the entire State of Illinois) for the
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Introduction
period April 1, 1997 to March 31, 2001; general ledgers;
tenant accounts receivable-occupancy reports; audited
financial statements; waiting list; rent rolls; and the
Authority’s policies and procedures.
We also reviewed: HUD’s files for the Housing Authority;
Sections 6 and 309 of the Annual Contributions Contract
between HUD and the Authority; Parts 85, 761, 886, 966,
and 990 of Title 24 of the Code of Federal Regulations;
HUD’s Public and Indian Housing Notice 96-35; HUD Form
52723-Calculation of Performance Funding System
Operating Subsidy; HUD Form 52267-Computation of
Payments-In-Lieu-Of-Taxes; HUD Form 52728-Housing
Authority Calculation of Occupancy Percentage for a
Requested Budget Year; and the Cooperation Agreement
dated August 19, 1958 between the Authority and the City
of Alton.
The audit covered the period April 1, 1997 to March 31,
2001. This period was adjusted as necessary. We
conducted the audit in accordance with generally accepted
government auditing standards.
We provided a copy of this report to the Housing
Authority’s Interim Executive Director and to the
Chairperson of the Board of Commissioners.
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Finding 1
The Authority Must Resolve Significant
Monetary Issues Totaling $280,796
The Housing Authority of the City of Alton did not follow HUD’s requirements, the Annual
Contributions Contract, and its policies to ensure the Housing Authority’s Low-Income Housing
and Public Housing Drug Elimination Programs were operated efficiently and effectively.
Specifically, the Housing Authority: (1) failed to make required tax payments totaling $50,870; (2)
claimed at least $38,823 in excess operating subsidies over a four year period; (3) did not make
sufficient efforts to collect tenant accounts receivable totaling $39,701; (4) inappropriately charged
expenses of $144,767 to its Drug Elimination Grants; and (5) improperly paid its former Executive
Director $6,635 for accrued but unused sick leave. The Housing Authority's former and current
Executive Directors did not exercise their responsibilities to implement effective controls over the
Authority’s Programs. As a result, HUD lacks assurance that the Housing Authority’s resources
were used to the maximum extent to benefit low and moderate income tenants.
24 CFR Part 990.109(b)(3)(iii)(B) states if the recalculated
HUD’s Requirements vacancy percentage is greater than three percent or more
than five vacant units, housing authorities will adjust their
requested budget year occupancy percentage by excluding
from their calculation of unit months available all units
vacant for longer than 12 months that are not vacant units
undergoing modernization or are not units vacant due to
circumstances and actions beyond authorities’ control.
These units are considered long-term vacancies.
24 CFR Part 990.109(b)(3)(iv)(A) requires that housing
authorities are to reduce their operating subsidy calculations
to 20 percent of the allowable expense level for long-term
vacancies. This requirement is also outlined in HUD’s
Public and Indian Housing Notice 96-35.
HUD Form 52723, Calculation of Performance Funding
System Operating Subsidy instructions, states housing
authorities should not include units defined as long-term
vacant units or units approved for non-dwelling use in the
calculation for unit months available. Housing authorities
receive operating subsidy from HUD based upon their unit
months available.
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Finding 1
24 CFR Part 761.15(d)(2) specifically states that costs
incurred prior to the effective date of a Public Housing Drug
Elimination Grant Agreement are ineligible expenses.
Section 6 of the Annual Contributions Contract, between
Annual Contributions HUD and the Housing Authority of the City of Alton,
Contract requires that during the development and operation of the
Housing Authority’s projects, the Authority will perform
and comply with all applicable provisions of the
Cooperation Agreement, including the provisions relating
to Payment-In-Lieu-Of-Taxes. In return for exempting the
Housing Authority’s low-income housing developments
from property taxes and special assessments, the Authority
agrees to remit Payment-In-Lieu-Of-Taxes to the local
governing body.
Section 309 of the Annual Contributions Contract requires
the Housing Authority to submit accurate and complete
financial data to HUD.
The Housing Authority’s Rent Collection Policy, effective
Housing Authority’s January 1, 1996, states prompt payment of rent and charges
Policies is required for continued occupancy by a public housing
resident. Payments not received by the Housing Authority on
the 10th day of each month are considered delinquent. On or
after the 11th day of the month, the Housing Authority will
serve the resident with a written Notice of Termination. The
Notice includes a demand for immediate payment of the
delinquent charges and a 14-day grace period before the
Housing Authority may begin the eviction process.
The Housing Authority’s 1982 Personnel Policy Benefits
Manual states an employee who is separated for
unsatisfactory job performance or resignation will not be
paid for any accumulated sick leave.
The Housing Authority was properly accruing for a liability
The Authority Did Not known as Payments-In-Lieu-Of-Taxes for Fiscal Years
Make Payments-In-Lieu- 1998 to 2000. However, the Authority failed to make any
Of-Taxes payments on the $50,870 owed to Madison County, Illinois.
The amount owed did not include Fiscal Year 2001.
Payment-In-Lieu-Of-Taxes is an assessment paid to the local
governing body having jurisdiction over a housing authority
in return for the governing body exempting the authority’s
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Finding 1
low-income housing developments from property taxes and
special assessments. The calculation of Payments-In-Lieu-
Of-Taxes is based on five percent of an authority’s dwelling
income (rental, non-rental, and excess utilities) less utility
expenses or the amount of the property taxes, if the
properties were not exempted, whichever is less.
The Housing Authority’s Independent Auditor reported this
situation as a finding in both the Fiscal Year 1998 and 1999
audit reports. The Authority’s Interim Executive Director
said he was uncertain why the Payments-In-Lieu-Of-Taxes
were not made on a timely basis. Payment of these monies
was the responsibility of the Housing Authority’s former
Executive Director who resigned from the Authority on
June 5, 2001.
On July 31, 2001, the Authority’s Interim Executive Director
sent a letter to the Madison County Treasurer’s Office
proposing to make twelve payments of $4,239 each
beginning September 2001. The Authority’s Interim
Executive Director said he intended to liquidate some of the
Authority’s investment securities to remit the payments.
As a result of the Housing Authority’s failure to make the
Payments-In-Lieu-Of-Taxes when due, the Annual
Contributions Contract and the Cooperation Agreement
between the Authority and Madison County were violated.
The Authority could have faced a severe cash shortage if the
County rejected the Authority’s payment proposal and
demanded that the funds be immediately paid in full.
The Housing Authority claimed and was paid at least
The Authority Claimed $38,823 in excess operating subsidy between April 1, 1997
Excess Operating Subsidy and March 31, 2001. Operating subsidies are paid to
For Long-Term Vacant housing authorities to cover the difference between an
Units allowable level of operating expenses and available income.
Because the Housing Authority included units that were
vacant for as long as 20 years in prior years’ operating
subsidy calculations, the total amount of excess subsidy
paid to the Authority is higher.
Four apartment complexes totaling 329 units are under the
Housing Authority’s jurisdiction. At least 20 years ago, six
units at the Joesting Terrace complex were vandalized and
the building’s water heater, furnace, and plumbing were
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destroyed. The Authority’s Board of Commissioners at that
time decided it would be too expensive to make repairs, so
the units were gutted but never rehabilitated for occupancy,
leaving only 323 units for occupancy.
When the Housing Authority’s former Executive Director
prepared the Calculation of Performance Funding System
Operating Subsidy forms, he used 329 units as the basis for
claiming subsidy rather than 323 units. We also determined
that in subsequent calculations the Authority’s former
Executive Director made estimates or used incorrect amounts
for the rent roll and units-occupied portions of the subsidy
calculations. HUD’s Illinois State Office of Public Housing
Hub made adjustments to the calculations based on verbal
information obtained from the Authority’s former Executive
Director; however, the information the former Director
provided was incorrect.
The Housing Authority’s former Executive Director said he
received training on how to complete HUD Form 52723 -
Calculation of Performance Funding System Operating
Subsidy. In addition, the Authority’s former Executive
Director said he received and read HUD’s Notices and
regulations regarding the calculation of operating subsidy for
long-term vacant units. However, the former Executive
Director said he was not aware that the six units were
included in the calculations for operating subsidies or that the
units should have been categorized as long-term vacancies.
The explanation by the Authority’s former Executive
Director is inconsistent since he acknowledges that he
received training on how to complete HUD Form 52723 and
read HUD’s requirements. Regardless, the Authority
received excess operating subsidies from HUD.
The Housing Authority’s incorrect reporting of long-term
vacancies resulted in the Authority receiving excess
operating subsidies between April 1, 1997 and March 31,
2001. The table on page 7 of this report shows the excess
subsidies paid to the Authority by Fiscal Year.
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Finding 1
Subsidy Corrected Excess
Fiscal Amount Paid Subsidy Due Subsidy
Year To Authority To Authority Paid
1997 $480,878 $482,862 $(1,984)
1998 498,649 474,811 23,838
1999 488,564 480,307 8,257
2000 508,653 499,941 8,712
Total $38,823
The excess subsidy paid to the Housing Authority for the
Fiscal Years shown above could have been used to support
the operations of other housing authorities or for other
program related purposes.
The Housing Authority did not make sufficient efforts to
The Authority’s Efforts collect its Tenants Accounts Receivable balance that totaled
To Collect Receivables $39,701 as of March 31, 2001. This amount was nearly
Were Poor equal to total rent receipts for a one-month period. In
addition, the Housing Authority violated its Rent Collection
Policy by extending collection efforts before it initiated
eviction procedures.
According to the Housing Authority’s Interim Executive
Director, the amount of the Authority’s Tenant Accounts
Receivable grew because more units were occupied, but an
increasing number of tenants did not meet their lease
obligations. Some tenants consistently paid late; thus,
incurring late charges that further increased the Receivable
balance. The Authority’s Interim Executive Director said he
began his collection efforts by going door-to-door to request
payment to avoid delivering 14-day eviction notices to
delinquent tenants. Several written Notices of Termination
were issued to at least 13 tenants more than once. In some of
these cases, the Housing Authority failed to follow through
with the eviction process and allowed residents to become
delinquent on rental payments for an average of three to
seven months.
The Housing Authority’s Rent Collection Policy requires
collection procedures to be initiated on or after the 11th day
of the month, if the tenant fails to make the required
payment. The Authority’s Interim Executive Director said he
did not actively pursue collection until tenants became two
months behind on their payments. Sometime during the
second month of not receiving payments, the Authority’s
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Finding 1
Interim Executive Director said he started the process of
issuing the 14-day notice.
The Housing Authority allowed tenants who were delinquent
on their rental payments, including those who were in the
eviction process, to arrange a payment plan to bring their
accounts current. According to the Authority’s Interim
Executive Director, most tenants made some type of payment
each month but the amount paid was never the minimum
amount due. Section B, paragraph 3(e)(ii), of the Authority’s
Rent Collection Policy states after the eviction process is
initiated, the tenant must make payment of all rent in arrears
in full and no partial payments will be accepted.
Between August 1998 and March 2001, the Housing
Authority wrote-off 129 delinquent tenant accounts totaling
$78,989. This included 14 tenants who made no rental
payments and 25 tenants who paid less than half of the
amount due. Unless the Housing Authority actively starts
to collect delinquent rents or evict tenants according to its
Rent Collection Policy, the Authority’s Tenants Accounts
Receivable balance will continue to increase. This situation
creates the possibility that the Authority may be unable to
meet its monthly expenses.
The Housing Authority improperly used Public Housing
The Authority Charged Drug Elimination Grant funds to pay expenses that were
Costs To Drug Grants incurred prior to the effective dates of the Grants, and for
Before The Grants Were expenses that were not eligible under the Drug Elimination
Awarded Grant Program.
HUD awarded Drug Elimination Grants totaling $246,474 to
the Housing Authority in 1998, 1999, and 2000 as follows:
Year of Award Amount of Award
1998 $98,700
1999 72,360
2000 75,414
Total $246,474
We reviewed all of the vouchers charged to the Authority’s
Public Housing Drug Elimination Grants for period April 1,
1997 to March 31, 2001. We considered these charges with
respect to the effective dates of each Grant, noting that
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Finding 1
$140,890 in expenses was improperly charged to the Grants
before their respective effective dates as follows:
Amount Charged Before
Year of Award Effective Date of Grant
1998 $ 85,038
1999 27,615
2000 28,237
Total $140,890
24 CFR Part 761.15 states costs incurred prior to the
effective date of the Grant Agreement are not allowable
expenses. The charges occurred between three to 11 months
before the Agreements’ effective dates. HUD’s Acting
Director of the Illinois State Office of Public Housing
Operations Division said expenses incurred prior to the
effective dates of the Grants should have been charged to the
specific Grant that was effective at the time the expenses
were incurred. As of March 26, 2002, there was only
$16,990 in funds left for the Authority to draw down from
the 1998 and 1999 Grants, and no monies were left from the
2000 Grant.
In addition, the Housing Authority charged $3,877 of
ineligible expenses to its Public Housing Drug Elimination
Grants as follows:
Amount
Ineligible Expense Charged
Stripping and waxing floors $1,695
Supplies for Christmas Party 105
Polo shirts for Housing
Authority’s staff and tablecloth
with Authority’s logo 379
Supplies for Thanksgiving Dinner 132
Supplies for Halloween Party 348
Winter caps for maintenance staff 96
Circus tickets 965
Food for chili cook-off and
resident council meeting 157
Total $3,877
The payment of expenses before the effective date of the
Public Housing Drug Elimination Grants and the ineligible
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Finding 1
expenses occurred because the Housing Authority’s
personnel responsible for administering the Grants were
unfamiliar with the Grants’ requirements. Also, the
Authority’s accounting controls were weak and not closely
supervised by the Board of Commissioners (see Finding 2).
The Housing Authority’s former Executive Director received
The Authority Improperly payment for $6,635 in accrued, but unused sick leave in
Paid Its Former Director violation of the Authority’s Personnel Policy Benefits
For Unused Sick Leave Manual.
Section C, paragraph 6, of the Housing Authority’s Personnel
Policy Benefits Manual states an employee who is separated
for unsatisfactory job performance or resignation will not be
paid for any accumulated sick leave. Paragraph 8 of the
Authority’s Manual states employees who have applied for
retirement will be permitted to receive pay for any unused
sick leave accumulated up to 90 days. The Authority’s
Board of Commissioners must approve the final payment of
the accumulated sick leave.
The Housing Authority’s former Executive Director did not
retire, but resigned from his position effective June 5, 2001.
Therefore, the former Director’s actions made him ineligible
to receive payment for the accumulated sick leave. The
Housing Authority was also unable to locate a Board of
Commissioners’ resolution that approved the payment. One
of the Authority’s Commissioners said he did not recall the
Board granting such approval.
The improper payment of the accumulated sick leave to the
Housing Authority’s former Executive Director occurred
because the Authority’s management did not adhere to its
Benefits Manual. Additionally, the Authority’s accounting
controls were weak and not closely supervised by the Board
of Commissioners (see Finding 2). As a result, HUD lacks
assurance that the Housing Authority’s resources were used
to the maximum extent to benefit low and moderate income
tenants.
Auditee Comments [Excerpts paraphrased from the Housing Authority of the
City of Alton’s comments on our draft finding follow.
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Finding 1
Appendix B, pages 29 to 31, contains the complete text of
the comments for this finding.]
The Housing Authority is presently making payments on its
past due Payment-In-Lieu-Of-Taxes. The first payment was
made in October 2001. The Housing Authority intends to
continue to make monthly payments until the past due
amount is paid in full. The Housing Authority will also pay
future obligations relating to Payment-In-Lieu-Of-Taxes as
the obligation comes due.
In regard to the Excess Performance Funding System
Operating Subsidy, it is the Housing Authority’s position that
the finding is correct in that the Authority currently has only
323 occupiable units. The Housing Authority agrees that it
received excess subsidy for the six units. The Housing
Authority’s Board of Commissioners authorized and directed
the Authority’s Interim Executive Director to deprogram the
six units from the Authority’s roles so the mistake will not be
repeated in the future.
The Housing Authority agrees that it failed to strictly comply
with the Rent Collection Policy. The Authority intends to
carefully review and revise its Policy in an effort to more
aggressively collect rents and accounts receivable. This will
include the filing of Citations to Discover Assets and Wage
Garnishments if current and former tenants who owe rent to
the Authority are currently employed.
The Authority will repay HUD $3,877 for the ineligible
expenses charged to the Drug Elimination Grants during the
audit period. The Housing Authority’s former Executive
Director informed the Board of Commissioners that the
expenditures were proper.
The Housing Authority believes that the finding requiring it
to seek recovery of $6,635 for sick leave paid in error to the
Authority’s former Executive Director is incorrect.
Apparently, the HUD audit personnel did not examine the
Housing Authority’s Personnel Policy Benefits Manual
adopted on April 1, 1997. It is the opinion of the Housing
Authority’s attorney that the Authority would be
unsuccessful in a court proceeding attempting to recover the
amount paid to the former Executive Director.
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Finding 1
OIG Evaluation Of We confirmed that the Housing Authority made six
Auditee Comments Payment-In-Lieu-Of-Taxes disbursements to Madison
County beginning in September 2001.
The April 1, 1997 revision to the Authority’s Personnel
Policy Benefits Manual makes no direct reference to the
issue of accumulated sick leave payments. Instead, the
Manual references and incorporates an earlier version of the
Policy, which does not directly mention this issue. In
reviewing the Authority’s Benefits Manual back to 1982 that
does make a direct reference to sick leave payments, the
1982 Manual permits payment of accumulated, unused sick
leave to employees who retired from the Authority.
Additionally, the Authority’s 1982 Benefits Manual
expressly prohibits such payments to employees who resign
from the Authority. Therefore, the Housing Authority was
not permitted to pay its former Executive Director for the
unused sick leave.
The actions planned by the Housing Authority, if fully
implemented, regarding the deprogramming of the six units
and collection of Tenant Accounts Receivable should
improve the Authority’s operations.
Besides repaying HUD $3,877 for the ineligible expenses
charged to the Public Housing Drug Elimination Grants, the
Housing Authority should also reimburse HUD for the
$140,890 in expenses that were improperly charged to the
Grants before their respective effective dates. Repayment
to HUD should be made from non-Federal funds.
Recommendations We recommend that the Illinois State Office Director of
Public Housing Hub assure that the Housing Authority of the
City of Alton:
1A. Makes all the required Payments-in-Lieu-of-Taxes
to Madison County.
1B. Reimburses HUD $38,823 from non-Federal funds
for the excess operating subsidy claimed between
April 1, 1997 and March 31, 2001.
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Finding 1
1C. Reimburses HUD $144,767 ($140,890 plus $3,877)
from non-Federal funds for the payment of costs
charged to the Grants before their effective dates and
the ineligible expenses paid from Grant funds.
1D. Takes any and all appropriate action to recapture the
$6,635 of unused sick leave that was improperly
paid to the former Executive Director. If the
Housing Authority is unable to recapture the money,
the Authority should reimburse the improper sick
leave payment from non-Federal funds to the
appropriate program.
1E. Implements procedures and controls to follow HUD’s
requirements, the Annual Contributions Contract,
and/or the Authority’s policies regarding: (1)
Payment-In-Lieu-Of-Taxes; (2) claims for operating
subsidies; (3) use of Public Housing Drug
Elimination Grant funds; and (4) payment of unused
sick leave.
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Finding 1
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Finding 2
The Authority Needs To Strengthen Its Controls
The Housing Authority of the City of Alton’s system of internal accounting and management
controls were weak. Specifically, controls did not assure that the Housing Authority adhered to its
own policies and procedures concerning performance appraisals, inventory of equipment, allocation
of unit size, tenant grievances, rental collections and evictions, and travel reimbursements to
members of the Board of Commissioners and the Authority’s staff for authorized travel. In
addition, the Board of Commissioners did not exercise adequate supervisory control over the
Authority’s financial activities and the former Executive Director. As a result, HUD’s and the
Housing Authority’s requirements were violated, and the Authority’s operations were not
conducted in an efficient and effective manner.
Management controls comprise the plan of organization,
Management Control methods, and procedures adopted by management to ensure
Requirements the safeguarding of resources against waste, loss, and misuse.
Management should establish physical controls to secure and
safeguard vulnerable assets. Periodic comparisons of
resources with the recorded accountability should be made to
help reduce the risk of errors, fraud, misuse, or unauthorized
alteration.
24 CFR Part 85.32 requires housing authorities to maintain
HUD’s Regulations detailed property records, take a physical inventory every
two years, and reconcile the inventory with property
records. Authorities’ records must show the property
description, source, title, cost, acquisition date, location,
use, and condition.
24 CFR Part 966.52 states housing authorities will furnish
each tenant and resident organization a copy of its
grievance procedures.
24 CFR Part 886.325 requires housing authority residents
to notify their authority if there is a change in the family's
composition and transfer to the appropriate sized unit.
Upon receipt of this notification, the authority agrees to
offer the family a suitable unit as soon as one becomes
vacant and ready for occupancy. The family will have
priority over individuals on the authority's waiting list
seeking the same sized unit.
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The Housing Authority’s Employee Manual, effective April
Authority’s Requirements 1997, requires annual performance appraisals to be done for
all of the Authority’s employees.
The Housing Authority’s By-Laws, dated March 19, 1986,
requires the Authority’s Secretary-Treasurer or designee to
have the care and custody of the Authority’s funds and
deposit the funds in the Authority’s bank account(s). The
Secretary-Treasurer will keep regular books of accounts
showing receipts and expenditures and will provide to the
Authority at each regular meeting, or more often if requested,
an account of transactions and the financial condition of the
Authority. The Secretary-Treasurer will keep in safe custody
the seal of the Authority and will have the power to affix
such seal to all contracts and instruments authorized for
execution by the Authority.
The Housing Authority's Travel Policy, effective March 4,
1997, states all travel outside of the Authority's jurisdiction
will be approved by Board resolution. The Policy also
states all travel expenses will be recorded, signed by the
traveler, and approved by the Authority’s Executive
Director prior to reimbursement.
The Housing Authority's Rent Collection Policy, dated
January 1, 1996, states after the 10th day of each month,
rent is considered delinquent and on the 11th day of the
month tenants will be served a termination notice by the
Authority.
The Housing Authority’s Inventory Control Policy requires
an inventory of materials and supplies be performed at least
once a year.
Public Housing Authority Commissioners have a
Responsibilities Of Board responsibility to HUD to ensure national housing policies are
Of Commissioners carried out, and to the Authority’s Executive Director and
employees to provide sound and manageable directives. The
Commissioners are accountable to their locality and best
serve it by monitoring operations to be certain that housing
programs are carried out in an efficient and economical
manner.
The Housing Authority’s Board of Commissioners did not
Commissioners’ maintain adequate oversight of the Authority’s assets and
Oversight Was Inadequate
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Finding 2
operations. The Commissioners were not completely aware
of their duties either as a Board or as individual officers
because significant Board responsibilities were left to the
Housing Authority’s former Executive Director, Quality
Control and Fiscal Director, and Office Manager.
As an example, the Housing Authority’s Secretary-
Treasurer was not adequately performing the financial
oversight or custodial responsibilities as required by the
Authority’s By-laws. The Secretary-Treasurer did not have
custody of the Housing Authority’s corporate seal, did not
properly control the Authority’s bank accounts and the
deposits made to those accounts, failed to keep proper
records showing receipts and expenditures, and generally
did not control the financial transactions of the Authority.
These duties were apparently delegated to the Housing
Authority’s staff; however, such delegation would have
required the Board of Commissioners to adopt a formal
resolution. The Authority was unable to provide us a
resolution that authorized the delegation of authority.
The Housing Authority’s Board of Commissioners said
they did not consistently receive reports of the Authority’s
financial condition from the former Executive Director. In
addition, the Commissioners said they did not fully
understand the reports they did receive that dealt with other
Housing Authority business matters. We observed Board
members signing the Authority’s checks without
thoroughly reviewing the supporting documentation. The
former Executive Director resigned from the Authority on
June 5, 2001. The Housing Authority’s former Executive
Director routinely presented disbursements to the
Authority’s Board without providing the purpose of the
disbursements.
During the course of the audit in May 2001, the Housing
Authority’s Secretary-Treasurer died; thus, creating more
uncertainty over the adequacy of the Authority’s controls.
As a result of the minimal oversight exercised by the
Housing Authority’s Board of Commissioners, the
Commissioners had inadequate knowledge of the
Authority’s financial condition. A stronger system of
management controls over the Authority’s assets and
activities of the former Executive Director would have
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Finding 2
avoided the previously cited problems, enabling the Board
to set appropriate and attainable goals for the Authority.
Between April 1, 1997 and March 31, 2001, the Housing
Performance Appraisals Authority’s Board of Commissioners did not perform
Were Not Conducted annual performance appraisals of the Authority’s former
Executive Director to achieve the annual goals set forth by
the Board. The Authority’s Employee Manual required
appraisals be performed of all of the Authority’s
employees. The Authority’s Commissioners said
performance evaluations were not completed for the former
Executive Director because he either did not make himself
available at the time his evaluations were scheduled or he
failed to provide requested information on his
accomplishments to facilitate the evaluations. Although
evaluations were not done, the Authority’s Board of
Commissioners awarded salary increases to the former
Executive Director between April 1997 and March 2001.
The Housing Authority violated HUD’s regulations
HUD’s Regulations concerning equipment inventory, unit size allocations, and
Regarding Inventory, Unit grievance procedures for tenants.
Allocation, And Tenant
Grievances Were Not The Housing Authority’s control over equipment was
Followed insufficient and inconsistent. Inventories were not performed
on a two-year cycle, and the Authority’s inventory records
lacked serial or identification numbers for all items of
equipment. Although the Authority’s personnel said an
inventory was performed in 1998, they were unable to
provide supporting documentation.
The Housing Authority allowed individuals and families,
including a Board Commissioner and Authority employees,
to occupy units for as long as seven years when they did not
meet the family composition guidelines to occupy the units.
This condition is known as over housing. In one case, an
individual tenant was housed in a three-bedroom unit since
1985. A one-bedroom unit is required by HUD’s regulation.
Appropriately sized units became available, but in most cases
the Housing Authority made no attempt to transfer the
tenants. As of September 10, 2001, 39 tenants appeared on
the Authority’s over housed list.
The Housing Authority’s written grievance procedures
included three of the four elements required by 24 CFR Part
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Finding 2
966.52. However, the Housing Authority did not provide a
copy of the grievance procedures to each tenant as required.
The Housing Authority’s Interim Executive Director and
other staff members said they were unaware of the
complete content of HUD’s regulation. The Authority’s
staff was aware that inventories of equipment were required
to be reconciled every two years, but they said they were
unaware that serial or identification numbers were also
required. The Housing Authority was unable to explain
why over housed tenants were not transferred to smaller
units. Personnel for the Authority said a copy of the
grievance procedures were posted in the Housing
Authority’s office lobby, but they said they were not aware
that a copy was required to be provided to each tenant.
As a result of these violations, the Housing Authority was
not operated in an efficient and effective manner.
Control procedures over the Housing Authority’s Board-
The Authority’s Rental approved Rent Collection and Travel Policies were weak.
Collection And Travel
Policies Were Violated The Authority’s Rent Collection Policy was not
consistently enforced with respect to tenant lease violations.
According to the Policy, tenants’ rents were considered
delinquent after the 10th day of the month. On the 11th
day, the Policy required that a non-paying tenant be served
with a termination notice. However, this was not always
done.
We reviewed 67 of the Housing Authority’s tenant files and
determined that in at least 10 cases, the Authority waited at
least two months to serve termination notices. Payment
agreements were then made between the Authority and
tenants, but the agreements were not enforced and eviction
actions were not taken. Additional delays in serving
termination notices may have occurred that were not
included in our review.
Travel completed and travel expenses claimed by the
Housing Authority’s personnel did not always comply with
the Authority’s Travel Policy. The Travel Policy required
that all travel outside of the Housing Authority's
jurisdiction (defined as the St. Louis metropolitan area and
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Finding 2
the entire State of Illinois) be approved by a Board
resolution.
Of the 45 trips taken by the Housing Authority’s personnel
between April 1, 1997 and March 31, 2001, 19 travel
vouchers were submitted. The Housing Authority was
unable to locate travel vouchers for the remaining 26 trips.
Of the 19, the Authority’s Board only adopted resolutions
authorizing six trips. All 19 trips required approval by the
Housing Authority’s Board in advance by resolution.
The Housing Authority’s Travel Policy also required that
all travel expenses were to be recorded, signed by the
traveler, and approved by the Authority’s Executive
Director prior to reimbursement. Of the 19 travel vouchers
submitted between April 1, 1997 and March 31, 2001, the
Housing Authority’s Executive Director approved only four
vouchers (21 percent).
The Housing Authority’s Interim Executive Director, who
previously served as the Authority’s Housing Manager, said
the former Executive Director controlled most of the
Authority’s operations and was responsible for the
situations previously noted.
As a result of the previously mentioned violations, the
Housing Authority’s tenant accounts receivable balance
steadily increased because the Authority failed to enforce
its Rent Collection Policy (see Finding 1). In addition, the
Authority exposed itself to unauthorized personal travel
because Board resolutions were not adopted and travel
vouchers were not consistently submitted or properly
processed.
In summary, management controls were extremely weak
because of the Housing Authority’s Board of
Commissioners and former Executive Director’s failure to
implement the necessary controls to ensure the Authority
was operated according to program requirements.
Auditee Comments [Excerpts paraphrased from the Housing Authority of the
City of Alton’s comments on our draft finding follow.
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Finding 2
Appendix B, pages 31 and 32, contains the complete text of
the comments for this finding.]
The Housing Authority’s Board of Commissioners and
employees intend to correct the problem of inadequate
oversight over the Authority’s assets and operations by
implementing additional training; additional oversight of the
reporting of the Authority’s financial condition; careful
review of expense check documentation prior to the signing
of checks; and annual performance appraisals of the
Executive Director and other employees.
The Housing Authority filed 10 new evictions and forcibly
evicted eight households. Seven households voluntarily
vacated their units after receiving either a Notice to
Terminate or a summons to appear in Court. The Authority
entered into Past Due Rent Repayment Plans with
approximately 30 tenants.
Travel expense vouchers will be more carefully reviewed and
the Executive Director will ensure that vouchers are
submitted for each trip taken by Housing Authority’s
personnel.
OIG Evaluation Of The actions planned by the Housing Authority, if fully
Auditee Comments implemented, should improve its controls over program
operations.
Recommendations We recommend that the Illinois State Office Director of
Public Housing Hub assure that the Housing Authority of the
City of Alton:
2A. Implements procedures and controls to assure that
HUD’s regulations and/or the Housing Authority’s
requirements are followed regarding performance
appraisals, inventory of equipment, allocation of unit
size, tenant grievances, rental collections and
evictions, and travel reimbursements.
We also recommend that the Illinois State Office Director
of Public Housing Hub:
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2B. Pursues administrative action against the Housing
Authority’s Board of Commissioners if within six
months they do not improve their oversight of the
Authority’s operations.
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Management Controls
In planning and performing our audit, we considered the management controls of the Housing
Authority of the City of Alton in order to determine our auditing procedures, not to provide
assurance on the controls. Management controls include the plan of organization, methods, and
procedures adopted by management to ensure that its goals are met. Management controls include
the processes for planning, organizing, directing, and controlling program operations. They include
the systems for measuring, reporting, and monitoring program performance.
We determined the following management controls were
Relevant Management relevant to our audit objectives:
Controls
· Program Operations - Policies and procedures that
management has implemented to reasonably ensure that a
program meets its objectives.
· Validity and Reliability of Data - Policies and procedures
that management has implemented to reasonably ensure
that valid and reliable data are obtained, maintained, and
fairly disclosed in reports.
· Compliance with Laws and Regulations - Policies and
procedures that management has implemented to
reasonably ensure that resource use is consistent with
laws and regulations.
· Safeguarding Resources - Policies and procedures that
management has implemented to reasonably ensure that
resources are safeguarded against waste, loss, and
misuse.
We assessed all of the relevant controls identified above.
It is a significant weakness if management controls do not
provide reasonable assurance that the process for planning,
organizing, directing, and controlling program operations
will meet an organization’s objectives.
Based on our review, we believe the following items are
Significant Weaknesses significant weaknesses:
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Management Controls
· Program Operations
The Housing Authority was not operated according to
program requirements. Specifically, the Authority: failed to
make required tax payments totaling $50,870; claimed at
least $38,823 in excess operating subsidies over a four year
period; did not make sufficient efforts to collect tenant
accounts receivable totaling $39,701; improperly charged
expenses of $144,767 to its Public Housing Drug
Elimination Grants; improperly paid its former Executive
Director $6,635 for accrued but unused sick leave; did not
perform annual performance appraisals of its former
Executive Director; failed to follow HUD’s regulations
regarding equipment inventory, unit size allocations, and
grievance procedures for tenants; and did not ensure that its
staff travel was properly authorized and travel expenses
complied with the Authority’s Policy (see Findings 1 and
2).
· Validity and Reliability of Data
The Housing Authority: provided inaccurate information to
HUD regarding the number of long-term vacant units; and
failed to include serial or identification numbers for
equipment in the Authority’s inventory records (see
Findings 1 and 2).
· Compliance with Laws and Regulations
The Housing Authority did not follow HUD’s regulations
regarding: requests for operating subsidies; payment of
expenses from its Public Housing Drug Elimination Grants;
controls over equipment; allocation of unit sizes; and
procedures concerning tenant grievances (see Findings 1
and 2).
· Safeguarding Resources
The Housing Authority improperly: claimed at least $38,823
in excess operating subsidies over a four year period; charged
expenses of $144,767 to its Public Housing Drug
Elimination Program; and paid its former Executive Director
$6,635 for accrued but unused sick leave (see Findings 1 and
2).
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Follow Up On Prior Audits
This is the first audit of the Housing Authority of the City of Alton by HUD’s Office of Inspector
General. The latest Independent Auditor’s Report for the Housing Authority covered the fiscal
year ended March 31, 2000. The Report contained three findings. One of the three findings is
reported in this report.
Independent Auditor’s Report This Report
The Authority Must Resolve Significant Monetary
Excessive Tenants Accounts Issues Totaling $280,796 and The Authority Needs
Receivable (Finding 1). To Strengthen Its Controls (Findings 1 and 2).
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Follow Up On Prior Audits
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Appendix A
Schedule Of Ineligible Costs
Recommendation
Number Ineligible Costs 1/
1B $ 38,823
1C 144,767
1D 6,635
Total $190,225
1/ Ineligible costs are costs charged to a HUD-financed or insured program or activity that the
auditor believes are not allowable by law, contract, or Federal, State, or local policies or
regulations.
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Appendix B
Auditee Comments
November 16, 2001
U.S. Department of Housing and Urban Development
Office of Inspector General for Audit, Midwest
77 West Jackson Boulevard, Room 2646
Chicago, Illinois 60604-3507
Attention: Ronald F. Huritz
In re: City of Alton Housing Authority Audit Findings
Dear Mr. Huritz:
The purpose of this letter is to respond to your letter of October 25, 2001 as requested.
The Alton Housing Must Resolve
Significant Monetary Issues
Totaling $318,085.00
The Alton Housing Authority admits the accuracy of the information in the “Criteria” section
except that the Housing Authority disagrees with the statement that “...an employee who is
separated for unsatisfactory job performance or resignation shall not be paid for any accumulated
sick leave.” is found in the Employee Manual of the Housing Authority of the City of Alton as
adopted on April 1, 1997. The quoted language is contained in prior Employee Manuals that
have been pre-empted by the April 1, 1997 Manual.
The Alton Housing Authority is presently making payments on its past due Payment in Lieu of
Taxes Obligation to the Madison County Treasurer pursuant to an oral agreement. The
agreement calls for payment of the past due amount owed to Madison County in the amount of
$50,870.00 in equal monthly installments of $4,239.00. The first of such payments was made in
October of 2001. The Housing Authority intends to continue to make monthly payments as
agreed until the past due amount is paid in full. The Housing Authority will also pay future
obligations relating to PILOT payments as the obligation comes due. The Board of
Commissioners of the Alton Housing Authority was not informed by the former Executive
Director that the Housing Authority failed to make the PILOT payments when due.
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Appendix B
In regard to the Excess Performance Funding System Operating Subsidy, it is the Housing
Authority’s position that the finding is correct in that the Housing Authority currently has only
323 occupiable units as indicated in the Audit finding. The Housing Authority agrees that it has
received excess subsidy for the six units for the audit period as indicated. The Board of
Commissioners of the Housing Authority has authorized and directed the Interim Executive
Director of the Housing Authority to deprogram the six units from the Housing Authority roles
so that the mistake will not be repeated in the future. Three of the units are the subject matter of
a Demolition Application to be submitted to HUD.
The Housing Authority agrees that it has failed to strictly comply with the Rent Collection Policy
of the Housing Authority. The Housing Authority intends to carefully review and revise its Rent
Collection Policy in an effort to more aggressively collect its rent and accounts receivables. The
Housing Authority has pursued a more aggressive eviction procedure that has resulted in the
following actions in the past 120 days:
1) The Housing Authority has filed ten (10) new evictions; and
2) The Housing Authority has forcibly evicted eight (8) households on which
prior Judgments of Possession had been obtained through the use of the
Madison County Sheriff’s Department; and
3) Seven (7) households have voluntarily vacated their units after receiving
either a Notice to Terminate Lease, or a Summons to appear in a State
Court; and
4) The Housing Authority has entered into Past Due Rent Repayment Plans
with approximately thirty (30) tenants.
The Alton Housing Authority also intends to more aggressively pursue collection of the post
occupation or post judgment Tenants Account Receivable balance. This will include the filing of
Citations to Discover Assets and Wage Garnishments if the tenants or former tenants owing rents
to the Housing Authority are currently employed.
The Alton Housing Authority has established a separate interest-bearing account and has
deposited $30,440.00 into that account to segregate the Tenant Security Deposits. Tenant
Security Deposits received in the future will be deposited into the account.
The Housing Authority will repay HUD $3,877.00 for ineligible expenses charged to Drug
Elimination Grants during the audit period. The Housing Authority Commissioners were told by
the former Executive Director that the expenditures were proper.
The Housing Authority has contacted its accountant and will adjust Housing Authority records to
associate expenses with the Drug Elimination Grant that was in effect at the time the expenses
were incurred. The Housing Authority Commissioners were unaware of the incorrect accounting
practice that occurred under the direction of the former Executor Director.
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Appendix B
The Housing Authority intends to seek technical assistance from HUD on accounting procedures
relating to Drug Elimination Grants and to provide proper training for its personnel on the proper
treatment of expenses incurred.
The Housing Authority believes that the finding requiring it to seek recovery of $6,635.00 for
sick leave paid in error to the former Executive Director is incorrect. Apparently, HUD audit
personnel did not examine the most recent Housing Authority Personnel Policy Benefits Manual
which was adopted on April 1, 1997. The current policy does not provide as indicated in the
HUD finding. In addition, certain employees (including the former Executive Director) were
promised that they would receive the accumulated sick pay upon severance of their employment.
It is the Housing Authority’s attorney’s opinion that the Housing Authority would be
unsuccessful in a court proceeding attempting to recover the amount paid to the former Executive
Director.
The Alton Housing Authority Must
Strengthen its Internal Controls
The Alton Housing Authority admits the accuracy of the information in the “Criteria” section.
However, the Housing Authority states that the By-Laws of the Housing Authority of the City of
Alton were amended on June 5, 2001 to delete the position of Secretary-Treasurer.
The Board of Commissioners and employees of the Housing Authority of the City of Alton
intend to correct the problem of inadequate oversight over the Housing Authority’s assets and
operations by the Housing Authority Commissioners implementing the following:
1) Additional Board of Commissioner training; and
2) Additional Board of Commissioner oversight of the reporting of the Housing
Authority’s financial condition; and
3) Board of Commissioner careful review of expense check documentation prior to
the signing of checks; and
4) Board of Commissioners annual performance appraisal of the Executive Director
position. The Board of Commissioners will further require job performance
appraisals to be made by the Executive Director relating to all Housing Authority
Department Heads; and
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Appendix B
5) The violation of the Federal Regulations concerning equipment inventory
requirements, unit size allocations, and grievance procedures for tenants will be
corrected and will not occur in the future.
6) That additional training for Housing Authority staff on Federal Regulations which
impact its programs and operations will be addressed.
The Housing Authority agrees that it has failed to strictly comply with the Rent Collection Policy
of the Housing Authority. The Housing Authority intends to carefully review and revise its Rent
Collection Policy in an effort to more aggressively collect its rent and accounts receivables. The
Housing Authority has pursued a more aggressive eviction procedure that has resulted in the
following actions in the past 120 days:
1) The Housing Authority has filed ten (10) new evictions; and
2) The Housing Authority has forcibly evicted eleven (11) households on
which prior Judgments of Possession had been obtained through the use of
the Madison County Sheriff’s Department; and
3) Seven (7) households have voluntarily vacated their units after receiving
either a Notice to Terminate Lease, or a Summons to appear in a State
Court;
4) The Housing Authority has entered into Past Due Rent Repayment Plans
with approximately thirty (30) tenants.
The Alton Housing Authority also intends to more aggressively pursue collection of the post
occupation or post judgment Tenants Account Receivable balance. This will include the filing of
Citations to Discover Assets and Wage Garnishments if the tenants or former tenants owing rents
to the Housing Authority are currently employed.
That Travel Expense Vouchers will be more carefully reviewed, and the Executive Director will
ensure that Travel Expense Vouchers are submitted for each trip taken by Housing Authority
personnel.
Very truly yours,
Housing Authority of the City of Alton
By____/signed/__________________________
Jeffrey W. Copley, Interim Executive Director
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Appendix C
Distribution
Regional Director, Midwest (2)
Director of Public Housing Hub, Illinois State Office (2)
Secretary, S (Room 10000)
Deputy Secretary, SD (Room 10100)
Senior Advisor to Deputy Secretary, SD (Room 10100)
Assistant to the Secretary for White House Liaison, S (Room 10216)
Press Secretary/Senior Communications Advisor to the Secretary, S (Room 10226)
Chief of Staff, S (Room 10000)
Acting Assistant Secretary for Administration, A (Room 10110)
Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120)
Director of Departmental Equal Employment Opportunity, U (Room 2112)
Deputy Chief of Staff for Policy and Programs, S (Room 10214)
Deputy Chief of Staff for Intergovernmental Affairs, S (Room 10214)
Director of Center for Faith-Based and Community Initiatives, K (Room 10184)
General Counsel, C (Room 10110)
Acting Assistant General Counsel, Midwest
Assistant Secretary for Housing-Federal Housing Commissioner, H (Room 9100)
General Deputy Assistant Secretary for Policy Development and Research, R (Room 8100)
Assistant Secretary for Community Planning and Development, D (Room 7100)
President of Government National Mortgage Association, T (Room 6100)
Acting Assistant Secretary for Fair Housing and Equal Opportunity, E (Room 5100)
Assistant Secretary for Public and Indian Housing, P (Room 4100)
General Deputy Assistant Secretary for Public and Indian Housing, P (Room 4100)
Acting Deputy Assistant Secretary for Public Housing Investments, PT (Room 4130)
Deputy Assistant CFO for Financial Management, FM (Room 2206)
Acting Deputy Assistant Secretary for Public and Assisted Housing Delivery, PH (Room 4204A)
Deputy Assistant Secretary for Administration and Budget/CFO, PC (Room 4234)
Audit Liaison Officer for Public and Indian Housing, PF (Room 5156)
Chief Information Officer, Q (Room P8206)
Director of Departmental Operations and Coordination, I (Room 2124)
Chief Financial Officer, F (Room 10234)
Director of Audit Coordination/Departmental Audit Liaison Officer, FMA (Room 2206)
Director of Risk Management, FMR (Room 2214)
CFO Audit Liaison Officer, FMA (Room 2206)
Audit Liaison Officer, 3AFI (2)
Director of Enforcement Center, V (200 Portals Building)
Acting Director of Multifamily Assistance Restructuring, Y (4000 Portals Building)
Acquisitions Librarian, Library, AS (Room 8141)
Acting Director of Federal Housing Enterprise Oversight, (1700 G Street NW, Room 4011)
Director of Healthy Homes and Lead Hazard Control, L (3206 Portals Building)
Chief Executive Officer, S (Room 10220)
Assistant Deputy Secretary for Field Policy and Management, M (Room 7108)
Special Counsel, C (Room 10126)
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Appendix C
Senior Advisor, Subcommittee on Criminal Justice, Drug Policy & Human Resources, B 373
Rayburn House Office Building, Washington DC 20515
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, Chairman, Committee on Governmental Affairs, 706 Hart
Senate Office Building, United States Senate, Washington DC 20510
The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn
Building, United States House of Representatives, Washington DC 20515
The Honorable Henry A. Waxman, Ranking Member, Committee on Government Reform,
2204 Rayburn Building, United States House of Representatives, Washington DC 20515
Associate Director of Housing and Telecommunications Issues, United States General
Accounting Office, 441 G Street N.W., Room 2T23, Washington DC 20548
Steve Redburn, Chief of Housing Branch, Office of Management and Budget, 725 17th Street,
N.W., Room 9226, New Executive Office Building, Washington DC 20503
Andy Cochran, House Committee on Financial Services, 2129 Rayburn House Office Building,
Washington DC 20515
Clinton C. Jones, Senior Counsel, Committee on Financial Services, B303 Rayburn Building,
United States House of Representatives, Washington DC 20515
Interim Executive Director, Housing Authority of the City of Alton (2)
Chairperson of the Board of Commissioners, Housing Authority of the City of Alton
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Housing Authority of the City of Alton, Low-Income Housing and Public Drug Elimination Programs Alton, Illinois
Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-03-29.
Below is a raw (and likely hideous) rendition of the original report. (PDF)