Issue Date
January 11, 2002
Audit Case Number
2002-FW-1001
TO: Katie Worsham
Director
Office of Community Planning and Development, 6AD
/SIGNED/
FROM: D. Michael Beard
District Inspector General for Audit, 6AGA
SUBJECT: Houston/Harris County/Coalition for the Homeless
Continuum of Care
Houston, Texas
We audited Houston/Harris County Continuum of Care 1996 and 1997 grants as part of a
nationwide review of HUD’s Continuum of Care Program. Our attached audit report contains
one finding. We have addressed our recommendations to your office due to HUD having no
grant or contractual agreement with the Houston/Harris County Continuum. We will provide
copies to the three entities comprising the collaborative: Harris County, City of Houston, and
Coalition for the Homeless.
Within 60 days please give us, for each recommendation made in this audit report, a status report
on: (1) corrective action taken; (2) proposed corrective action and date to be completed; or (3)
why action is considered unnecessary. Also, please furnish us copies of any correspondence or
directive issued because of this audit.
If you have any questions, please call William Nixon, Assistant District Inspector General for
Audit, at (817) 978-9309.
Management Memorandum
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2002-FW-1001 Page ii
Executive Summary
We audited the Houston/Harris County Continuum of Care (Continuum) 1996 and 1997
grants. Our audit objectives were to determine whether the Continuum had adequate
management controls to ensure that it: (1) developed a strategic plan that fairly
represented the community’s needs; (2) had a representative membership; (3) had a fair
funding process; (4) held its members accountable for their performance; and (5) tracked
participant progress.
Audit Results. Our audit concluded the Continuum had adequate
management controls to ensure it: (1) developed a strategic
plan that fairly represented the community’s needs; (2) had
a representative membership; and (3) had a fair funding
process. However, the Continuum did not administer its
Continuum of Care Programs according to the terms and
conditions of its consolidated applications. Specifically, it
did not have sufficient management controls to measure its
members’ performances and to gather, track, record, and
report critical program data.
As a result, the Continuum did not know which members
were performing as planned in order to hold them
accountable for their performance. Additionally, it could
not provide evidence it met HUD’s goal of helping
homeless individuals and families “transition from the
streets to jobs and independent living.”
Through Continuum of Care Programs, HUD planned for
communities to coordinate their housing and service
delivery system, not only during the grant application
process, but also throughout grant programs, to ensure the
community met the needs of homeless individuals and
families. Contradicting plans submitted to HUD, the
Continuum did not coordinate its programs once HUD
awarded grant funds. The Continuum believed it was only
responsible for coordinating the consolidated grant
application process.
We recommend HUD encourage the Continuum to develop
Recommendations. and implement a process for evaluating program
effectiveness and participant outcomes. HUD should
persuade the Continuum to establish policies and
procedures so that its members: (1) coordinate services
among themselves; (2) serve only homeless individuals and
Page iii 2002-FW-1001
Executive Summary
families; and (3) track participants throughout the
Continuum of Care system to ensure participants’ transition
to jobs and independent living.
We provided a draft of this report to HUD’s Fort Worth
Auditee Comments.
Community Planning and Development Director on
October 11, 2001. HUD provided written comments on
November 29, 2001, and we held an exit conference on
December 7, 2001. We have summarized and evaluated the
response in the findings and included the written response
in its entirety as Appendix A. Based upon their response,
we modified the report, where appropriate. While HUD
generally agreed with the finding, it believed the
recommendations should be modified to reflect the lack of
authority that HUD has over the Continuum.
2002-FW-1001 Page iv
Table of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Finding
1 Supportive Housing Programs Not Managed 11
Management Controls 17
Appendices
A Auditee Comments 19
B Distribution 23
Page v 2002-FW-1001
Table of Contents
Abbreviations
BLOCK Building Lives Offering Community Knowledge
Campus University of Texas – Houston Recovery Campus
CFR Code of Federal Regulations
Circular Office of Management and Budget Circular A-122, Cost
Principles for Non-Profit Organizations
Coalition Coalition for the Homeless
Continuum Houston/Harris County Continuum of Care
County Harris County
Foundation AIDS Foundation Houston, Inc.
Grantees Houston/Harris County Continuum of Care members
awarded Continuum of Care grants
HUD U.S. Department of Housing and Urban Development
OIG Office of Inspector General
Resource Group Houston Regional HIV/AIDS Resource Group, Inc.
S+C Shelter Plus Care Program
SHP Supportive Housing Program
SRO Section 8 Moderate Rehabilitation for Single Room
Occupancy Dwellings
Trinity Trinity Life Center
2002-FW-1001 Page vi
Introduction
Background The McKinney-Vento Homeless Assistance Act authorized
HUD’s Continuum of Care Programs. HUD initiated the
Continuum of Care Programs to address the needs of
homeless individuals and families to enable them to leave
“the streets”, acquire jobs, and obtain independent living.
HUD used its Continuum of Care Programs to encourage
communities to form a comprehensive housing and service
delivery system to meet the needs of their homeless
subpopulations. The Continuum of Care concept included
three major competitively funded programs: (1) Supportive
Housing; (2) Shelter Plus Care; and (3) Section 8 Moderate
Rehabilitation for Single Room Occupancy Dwellings
(SRO).1
HUD planned the Supportive Housing Program to promote
the development of supportive housing and services for
homeless individuals to live as independently as possible.
The program encouraged the use of innovative approaches
to assist homeless persons.
HUD designed the Shelter Plus Care Program to provide
rental assistance for hard-to-serve homeless individuals
with disabilities. Other sources outside the program
provided funds for supportive services.
HUD believed carefully planned and systemic local
approaches, or Continuum of Care systems, were more
effective and efficient than disconnected approaches.
Therefore, it placed heavy emphasis on programs designed
and carried out through Continuum of Care systems. To
provide communities maximum flexibility, HUD issued no
regulations governing the operation or organization of the
individual Continuum of Care organizations.
Three agencies comprised the Continuum: (1) the City of
Houston Housing and Community Development
Department; (2) Harris County Community Development
Department; and (3) Coalition for the Homeless of
Houston/Harris County (Coalition). The City of Houston
and Harris County are government agencies and the
Coalition is a nonprofit organization.
1
According to the applications, the Continuum did not apply for SRO funding for 1996 and 1997, the period we audited.
Page 1 2002-FW-1001
Introduction
The City of Houston Housing and Community
Development Department is located at 601 Sawyer,
Houston, Texas. Harris County Community Development
Department is located at 8410 Lantern Point, Houston,
Texas. The Coalition is located at 1301 Travis, Suite No.
1701, Houston, Texas.
Grant award process. Prior to submitting its consolidated grant application to
HUD, the Continuum provided technical assistance and
workshops for individual agencies competing for
Continuum of Care funds. After the Continuum received
the individual grant applications, it scored them and then it
ranked the proposed programs based on the homeless
community’s needs. The Continuum then selected
programs to include in its consolidated application for
HUD funding. The Continuum’s consolidated application
not only described the individual agencies and their
proposed programs, but also explained the Continuum’s
organization and strategic plan.
HUD reviewed and rated all applications using the same
procedures. It first conducted a threshold review of each
proposed program for the criteria identified in the Notice of
Funding Availability, eliminating all programs from the
competition that did not meet the specified criteria.
Next, HUD assigned up to 40 points for the community’s
fundamental need to provide housing and services for
homeless persons and up to 60 points for the community’s
Continuum of Care strategic plan. Thus, HUD established
funding decisions based upon the Continuum’s strategic
plan listed in its consolidated application.
2002-FW-1001 Page 2
Introduction
Grant funds awarded to the Number Total SHP Number
Continuum. of SHP2 Amount of S+C3 Total S+C
Grant Grants Awarded Grants Amount
Year Awarded Awarded Awarded
1996 19 $11,177,351 9 $6,302,580
1997 18 11,169,632 1 108,960
Totals4 37 $22,346,983 10 $6,411,540
HUD awarded Supportive Housing Program grants in part
based on Continuum members’ stated ability to provide
measurable results. Once HUD approved their programs,
agencies entered into grant agreements with HUD. By
signing the grant agreements, Continuum members
accepted responsibility for ensuring they used HUD funds
in accordance with all program requirements and written
agreements.
HUD required Continuum members to submit Annual
Progress Reports detailing progress in achieving
performance measures. Members were responsible for
information submitted in the Annual Progress Reports just
as the Continuum was responsible for the strategic plan
listed in its consolidated applications.
Continuum strategic plan. HUD believed the best approach for alleviating
homelessness was through a community-based process
providing a comprehensive response. Under the 1997
consolidated application, the Continuum listed the
following strategies to achieve the ultimate goal of helping
participants’ transition from homelessness to jobs and
independent living:
1. Develop formal and informal multi-agency
collaboration;
2. Link information, processes and program participants
among the collaborating and independent agencies;
3. Evaluate program effectiveness and participant
outcomes;
4. Encourage a variety of agency types to address the
needs of similar subpopulations;
2
Supportive Housing Program.
3
Shelter Plus Care Program.
4
HUD awarded $3,903,752, or 17.5 percent of $22,346,983 total Supportive Housing Program funds, to Harris County. HUD
awarded all of the $6,411,540 Shelter Plus Care funds to Harris County.
Page 3 2002-FW-1001
Introduction
5. Identify and access multiple funding sources that can
be integrated into a comprehensive funding system;
and
6. Expand the power base of the local service providers,
the Homeless Services Coordinating Council and the
Coalition for the Homeless of Houston/Harris County.
The 1996 and 1998 through 2000 consolidated applications
generally contained the same strategic plan, including
quality assurance and program evaluation goals. Those
applications also listed the strategy of linking information,
processes, and program participants among the
collaborating and independent agencies. In its 1996
through 2000 grant applications, the Continuum assured
HUD that it was developing a program “…to track the
movement of participants through the system into
permanent self-sufficiency.”
The Continuum planned to provide quality assurance and
program evaluation utilizing the Annual Progress Reports
prepared by individual grantees. It also planned to meet its
goal by collecting and analyzing data in its tracking system,
the Computerized Homeless Network.
Audit Objectives, Scope, Our audit objectives were to determine whether the
and Methodology Continuum had adequate management controls to ensure
that it: (1) developed a strategic plan that fairly represented
the community’s needs; (2) had a representative
membership; (3) had a fair funding process; (4) held its
members accountable for their performance; and (5) tracked
the progress of programs and participants.
To accomplish our objectives, we reviewed documents
from the County and the Coalition; and interviewed HUD,
the County, the City of Houston, and Coalition officials.
We reviewed and analyzed the Continuum’s consolidated
applications for 1996 through 2000; reviewed and analyzed
the Continuum’s policies and procedures; and audited three
Continuum of Care grants awarded to the following
agencies: AIDS Foundation Houston, Inc., Houston
Regional HIV/AIDS Resource Group, Inc., and Harris
County, as detailed in the chart below. During the audits of
2002-FW-1001 Page 4
Introduction
the grantees, we also performed audit work at 13
subrecipient locations under the same grants.5
In order to develop conclusions on the Continuum, we
reviewed applicable criteria, including Office of
Management and Budget Circular A-122, Cost Principles
for Non-Profit Organizations (Circular); reviewed grantee
and subrecipient policies and procedures, grant
applications, grant agreements, technical submissions, and
Annual Progress Reports; interviewed grantees and
subrecipients; visited transitional housing locations;
reviewed and analyzed participant files; and reviewed and
analyzed financial records.
Grants audited.
Agency Grant Grant Number Grant
Year/Program Amount
AIDS Foundation 1997 Supportive TX21B-97-1304 $3,000,645
Houston, Inc. Housing Program
(Foundation)6
Houston Regional 1996 Supportive TX21B-96-0617 1,332,281
HIV/AIDS Housing Program
Resource Group,
Inc. (Resource
Group)7 8
Harris County 1997 Supportive TX21B-97-1306 1,096,530
(County)9 Housing Program
Total $5,429,456
Overall, we audited $5,429,456, or 24.3 percent of
$22,346,983 Supportive Housing program funds and 18.9
percent of $28,758,523 total funds, awarded to the
Continuum for 1996 and 1997.
5
The subrecipients were (1) A Friendly Haven; (2)The Arrow Project; (3) Building Lives Offering Community Knowledge
(BLOCK); (4) CASA de Nino; (5) Milam House; (6) OMNI; (7) People With AIDS Coalition; (8) Stevens House; (9) Vita
Living; (10) Covenant House Texas; (11) DePelchin Children’s Center; (12) Trinity Life Center; and (13) University of Texas
– UT Houston Recovery Campus.
6
Audit Memorandum number 2001-FW-1803, issued on March 9, 2001.
7
Audit Memorandum number 00-FW-251-1806, issued on September 27, 2000.
8
Audit Memorandum number 00-FW-251-1805, issued on September 5, 2000.
9
Audit Memorandum number 2001-FW-1805, issued on April 27, 2001.
Page 5 2002-FW-1001
Introduction
HUD did not require the Continuum to enter into any type
of signed agreement concerning its role in the Continuum
of Care process. As a result, the Continuum did not believe
it was responsible for ensuring that its members, including
the Foundation, the Resource Group, and the County,
accomplished their program goals.
The Foundation, the Resource Group, and the County
entered into grant agreements with HUD. The grant
agreements, including the grant applications, delineated the
agencies’ responsibilities within the Continuum of Care
system. The Foundation, the Resource Group, and the
County submitted their grant applications as part of the
Continuum’s consolidated applications.
HUD based its decision to fund member programs on the
Continuum’s consolidated applications. The Continuum
based its consolidated applications on strategies developed
by combining the objectives of the individual grant
applications submitted to HUD by its members. As a
result, the Continuum was responsible for achieving the
strategies that it proposed in those applications. We
compared the Continuum’s strategies to its results to
determine whether its policies, procedures, and
management controls met the needs of homeless
individuals and families as discussed in its applications.
During our audit, we became aware of a complaint
concerning the Continuum’s program selection process for
its 2000 consolidated application. The complainant wrote
the Continuum used a “flawed” process of ranking
proposals for its 2000 grants, causing it to rank proposals
with lower scores above those with high scores. The
complaint alleged the Continuum allowed “personalities
and misinformation” to guide its decisions concerning
funding matters. We could not substantiate the complaint.
During our audit, we obtained computer-generated data
from both HUD and the grantees. However, we did not
perform any tests on the validity or reliability of such data
except as noted in the findings and management controls.
We performed audit work at the Foundation, the Resource
Group, and the County for the period May 23, 1997,
through July 31, 2000. We performed our audit between
January 2000, and March 2001. We conducted our audit in
2002-FW-1001 Page 6
Introduction
accordance with generally accepted government auditing
standards.
Grant audit results. We summarized the results of our grant audits below.
The Foundation
Our audit concluded the Foundation and its subrecipients
generally implemented grant activities consistent with the
grant application. The Foundation maintained evidence of
measurable results, leveraged HUD funds adequately,
expended funds timely, and met federal requirements
related to leasing. Additionally, the Foundation provided
sufficient technical assistance to its subrecipients and
reviewed their single audit reports and monthly expense
reports.
However, the Foundation expended funds for ineligible and
unsupported activities and did not comply with federal cost
requirements. The Foundation reimbursed the BLOCK, a
subrecipient, $42,091 for ineligible and unsupported
costs.10 The Foundation also used HUD funds to reimburse
itself $27,278 for ineligible costs, including $2,706 for an
ineligible participant and $1,483 for a computer that the
BLOCK used for financial purposes as opposed to tracking
participants as authorized by HUD.
The Resource Group
Our audit concluded the Resource Group generally
implemented its activities consistent with its application.
The Resource Group provided adequate technical assistance
to its subrecipients. It also reviewed its subrecipients’
single audit reports, monthly expense reports, and Annual
Progress Reports.
However, Trinity Life Center (Trinity) and Covenant
House, two subrecipients, did not maintain sufficient
documentation to determine that a sample of program
participants met HUD’s homeless requirements. As a result
of Trinity’s insufficient file documentation, the Resource
Group could not accurately conclude it served the intended
population. We attributed the problems to staff not
10
Ineligible $14,888; unsupported $27,203.
Page 7 2002-FW-1001
Introduction
knowing HUD requirements related to documenting
homelessness.
Trinity did not maintain support for its accomplishments it
reported to the Resource Group and subsequently to HUD.
Accordingly, the Resource Group could not conclude
whether it met the purpose of the grant program. The
Resource Group reported the erroneous information to
HUD in its Annual Progress Reports.
Trinity did not provide housing that met standards required
by the grant agreement.11 In addition, Trinity did not have
evidence that it analyzed the rent for reasonableness. As a
result, HUD had no assurance it paid reasonable rents for
participants. Further, the Resource Group inappropriately
reimbursed Trinity $182,398 for ineligible and unsupported
costs.12
Harris County
Our audit concluded the County’s activities were eligible
and consistent with its application and it adequately
leveraged HUD funds and met federal cost requirements.
However, the County’s subgrantee, University of Texas –
Houston Recovery Campus (Campus), could not support
information contained in its Annual Progress Report;13 did
not capture necessary housing data; and did not provide its
participants with decent, safe, and sanitary housing.
Additionally, the Campus charged HUD unreasonable
rents. A HUD contractor expressed concerns about rent
reasonableness and the County responded with unrealistic
comparable units. Disregarding HUD requirements, the
Campus charged participants a flat rental rate of $85 per
month without considering the participant’s monthly
income. Further, the County did not draw down its funds
timely because it had reconciliation and documentation
problems.
We provided a draft of this report to HUD's Fort Worth
Community Planning and Development Director on
11
See 24 CFR 583.300(b).
12
Including $100,259 paid for participants with no evidence of homelessness.
13
The Campus reported a 79% successful graduation rate even though its files indicated a 26% rate.
2002-FW-1001 Page 8
Introduction
October 11, 2001. HUD provided written comments on
November 29, 2001, and we held an exit conference on
December 7, 2001. We have summarized and evaluated the
response in the findings and included the written response
in its entirety as Appendix A. Based upon their response,
we modified the report where appropriate. While HUD
generally agreed with the finding, it believed the
recommendations should be modified to reflect the lack of
authority that HUD has over the Continuum.
Page 9 2002-FW-1001
Introduction
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2002-FW-1001 Page 10
Finding
Supportive Housing Programs Not Managed
The Continuum did not administer its programs in accordance with its consolidated
applications. The Continuum did not have a system in place to evaluate program
effectiveness and participant outcomes, or a management information system to timely
gather, track, record, and report critical program data to Continuum management and to
HUD.
The lack of management controls negatively impacted program effectiveness and efficiency.
For instance, the Continuum did not obtain measurable results for addressing
homelessness. The Continuum did not have management controls for verifying members
maintained adequate documentation of homelessness as required by HUD, and members
expended funds only for eligible participants. As a result, it did not know whether or not its
programs met the community’s needs or even that participants obtained and remained in
permanent housing.
The Continuum did not have adequate management
The Continuum did not have
controls to evaluate members’ performance or even monitor
sufficient management
the effectiveness of its Continuum of Care system.
controls to measure
Grantees reported erroneous information in their Annual
members’ performance.
Progress Reports, giving HUD and the Continuum the false
impression they met the goals outlined in their applications
for funding. The Continuum did not ensure the Annual
Progress Reports were correct and coordinated.
Additionally, it did not have procedures in place to monitor
the effectiveness of the Continuum of Care system. As a
result, it did not know which members performed as
planned.
According to the Continuum’s applications, it planned to
evaluate program effectiveness and participant outcomes.
However, the Continuum did not perform any independent
analyses of its Continuum of Care system.
Contrary to its 1996 through 2000 consolidated grant
The Continuum did not have
applications, the Continuum did not have management
management controls to
controls necessary to track participant’s progress.
ensure tracking of
According to those applications, the Continuum planned to
participant progress.
install a computerized tracking system throughout the
Houston/Harris County area to track participants.
Additionally, the 1998 and 1999 consolidated applications
stated the Continuum was developing an evaluation
Page 11 2002-FW-1001
Finding
program from data in the Computerized Homeless
Network, even though the Continuum never used such a
Network.
To complement the Continuum’s plans for tracking, the
Foundation, the Resource Group, and the County planned
to implement their own tracking systems. Both the
Foundation and the County described their plans to track
participants in their 1997 grant applications. Additionally,
the Foundation notified HUD that they planned to set up a
tracking system with the Resource Group.
Although the Resource Group and the County signed grant
agreements requiring them to track departing participants,
neither Trinity nor the Campus captured housing related
data. These subrecipients, along with Covenant House, did
not track grant participants.
Directly contradicting its consolidated applications, the
Continuum did not ensure that its members used sufficient
tracking systems. As of March 30, 2001, the Continuum
had not implemented its community-wide tracking system.
As a result, the Foundation, the Resource Group, and the
County did not use tracking systems as of our last day of
fieldwork at each location. Our last day of fieldwork at:
the Foundation was November 2000; the Resource Group
was May 2000, and the County was March 2001.
Although HUD did not issue any requirements regarding
The Continuum had an
the Continuum, the Continuum nonetheless had an
obligation to ensure
obligation to develop and implement procedures to aid its
members met its goals.
members to meet their goals. The Continuum promised
HUD it would take an active part in accomplishing program
goals through the strategies summarized in its applications.
HUD relied upon the Continuum’s strategies during its
conditional selection process.
The Continuum planned to implement policies and
procedures to evaluate program effectiveness and
participant outcomes. Those policies and procedures would
encourage members to more thoroughly examine their
program outcomes. Thus, members may have provided
additional support and critical evaluation of subrecipients.
Unfortunately, the Continuum did not have a system in
2002-FW-1001 Page 12
Finding
place to evaluate its members’ programs. Thus, allowing
members’ assertions to go unchallenged.
As reported in previous audit memorandums, Continuum
members did not have evidence to support claims
concerning program goals achieved or even that they served
the intended population. Not only did Continuum members
fail to maintain adequate supporting documentation of
costs, they incorrectly paid grant funds for costs clearly
disallowed by the Circular.
Additionally, the Continuum did not have procedures to
detect that the Resource Group and the County provided
unacceptable housing for grant participants, many who
were teenagers and young adults, or that the County paid
excessive rents with HUD funds.
Furthermore, the Continuum could not substantiate the
activities reported to HUD in its Consolidated Applications.
For example, the 1999 Consolidated Application included
the following statements:
“Each recipient of HUD Homeless Assistance funds is
provided with a computer, software, connection and
training for participating in a region-wide computerized
information and client tracking network. The system
ties together homeless service providers and the
Coalition with a uniform intake/assessment/case
management and tracking system.”14
“The Collaborative is currently developing a plan of
action to implement a broad-based multi-site process
and outcome evaluation, coupled with an assessment of
the data collected by tracking participants through the
Computerized Homeless Network.” 15
“The network is the underpinning of a measurement
data base, forming a quantifiable baseline of
information and empirical data to backup agency
determinations and reports. Analysis of the data serves
to track participants through the seamless system,
monitor service populations by subgroup and
14
Houston/Harris County, Texas 1999 Consolidated Application: Linking of information, processes and program participants
throughout the system.
15
Houston/Harris County, Texas 1999 Consolidated Application: Evaluation of program effectiveness and participant
outcomes.
Page 13 2002-FW-1001
Finding
geographic distribution, and to measure the cost
effectiveness of service programs.” 16
The Continuum provided erroneous information to HUD in
its consolidated applications because it never used or
implemented a tracking system. Thus, the Continuum gave
the false impression that it could implement its strategies
when it did not even have the necessary resources to do so.
Additionally, the Continuum did not document it had
provided adequate outreach work or any other planned
activities to enable homeless individuals and families to
leave the streets, obtain jobs, and become self-sufficient.
HUD provided a written response on November 29, 2001.
Auditee Comments We have included its response in its entirety as Appendix
A. HUD generally agreed with the conclusions in the draft
report. However, HUD did not believe it had "any basis"
for requiring the Continuum to implement systems or
procedures. Also, HUD noted the Continuum has not
requested or received any funds therefore may not have the
ability to monitor grantees.
OIG Evaluation of We agree HUD does not have the regulatory authority to
Comments compel the Continuum to comply with its application.
Further, during our audit period, HUD did provide training
to grantees. HUD should continue to work with the
Continuum and its members to ensure that the Continuum
meets the objectives of the program and of its applications.
We made changes to the draft report where necessary.
Recommendations We recommend that HUD:
1A. Persuade the Continuum to develop and implement a
process to evaluate program effectiveness and
participant outcomes so as to meet their application.
The Continuum should have policies and procedures
so that its members: (1) coordinate services among
16
Houston/Harris County, Texas 1999 Consolidated Application: Quality Assurance/Program Evaluation.
2002-FW-1001 Page 14
Finding
themselves; (2) serve only homeless individuals and
families; and (3) track participants throughout the
Continuum of Care system to ensure participants
transition to jobs and independent living.
1B. Continue to provide technical assistance workshops
for grantees and Continuum members throughout the
grant. The technical assistance should focus on the
following areas: basic program requirements; HUD
homeless eligibility requirements; establishing and
maintaining complete and accurate participant
records; creating and retaining sufficient fiscal
records; and Annual Progress Report preparation.
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Finding
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2002-FW-1001 Page 16
Management Controls
In planning and performing our audit, we obtained an understanding of the management
controls relevant to our audit. Management is responsible for establishing effective
management controls. Management controls, in the broadest sense, include the plan of
organization, methods, and procedures adopted by management to ensure that the goals
are met. Management controls include the processes for planning, organizing, directing,
and controlling program operations. They include the systems for measuring, reporting,
and monitoring program performance.
Significant Controls. We determined the following management controls were
relevant to our audit objectives:
· Fair representation of the needs of the community;
· A representative membership;
· A fair funding process;
· Accountability of performance; and
· Tracking of program progress and participants.
Significant Weaknesses. It is a significant weakness if management controls do not
give reasonable assurance that resource use is consistent
with laws, regulations, and policies; that resources are
safeguarded against waste, loss, and misuse; and that
reliable data is obtained, maintained, and fairly disclosed in
reports. As discussed in the finding, we believe the
following items are significant weaknesses in that the
Continuum lacked sufficient controls to ensure:
· Accountability of performance and
· Tracking of program progress and participants.
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2002-FW-1001 Page 18
Appendix A
Auditee Comments
Page 19 2002-FW-1001
Appendix A
2002-FW-1001 Page 20
Appendix A
Page 21 2002-FW-1001
Appendix A
2002-FW-1001 Page 22
Appendix B
Distribution
City of Houston/Harris County/Coalition for the Homeless. Houston, TX
Principal Staff
Secretary's Representative, 6AS
CFO, 6AF
Director, Accounting, 6AAF
Director, Office of Community Planning & Development, 6AD
Fort Worth ALO, 6AF (2)
CPD ALO, DOT (Room 7220)
Department ALO, FM (Room 2206)
Acquisitions Librarian, Library, AS (Room 8141)
Armando Falcon
Director, Office of Federal Housing Enterprise Oversight
1700 G Street, NW, Room 4011, Washington, D.C. 20515
Sharon Pinkerton
Sr. Advisor, Subcommittee on Criminal Justice, Drug Policy &
Human Resources
B373 Rayburn House Ofc. Bldg., Washington, D.C. 20515
Cindy Fogleman
Subcommittee on General Oversight & Investigations, Room 212
O'Neill House Ofc. Bldg., Washington, D.C. 20515
Stanley Czerwinski
Associate Director, Housing. & Telecommunications Issues
US GAO, 441 G St. NW, Room 2T23, Washington, DC 20548
Steve Redburn
Chief, Housing Branch, OMB
725 17th Street, NW, Room 9226, New Exec. Ofc. Bldg., Washington, D.C. 20503
The Honorable Fred Thompson
Chairman, Committee on Govt Affairs,
340 Dirksen Senate Office Bldg.
U.S. Senate, Washington, D.C. 20510
The Honorable Joseph Lieberman
Ranking Member, Committee on Govt Affairs,
706 Hart Senate Office Bldg.
U.S. Senate, Washington, D.C. 20510
Page 23 2002-FW-1001
Appendix B
The Honorable Dan Burton
Chairman, Committee on Govt Reform,
2185 Rayburn Building
House of Representatives, Washington, D.C. 20515-6143
Henry A. Waxman
Ranking Member, Committee on Govt Reform,
2204 Rayburn Bldg.
House of Rep., Washington, D.C. 20515-4305
Andrew R. Cochran
Sr. Counsel, Committee on Financial Services
2129 Rayburn, HOB
House of Rep., Washington, D.C. 20510
2002-FW-1001 Page 24
Houston/Harris County/Coalition for the Homeless Continuum of Care Houston, Texas
Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-01-11.
Below is a raw (and likely hideous) rendition of the original report. (PDF)