oversight

Housing Authority of Champaign County Citizen Complaint Champaign, Illinois We have completed an audit of the Housing Authority of Champaign County.

Published by the Department of Housing and Urban Development, Office of Inspector General on 2002-10-24.

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

                                                              Issue Date
                                                                      October 24, 2002
                                                              Audit Case Number
                                                                      2003-CH-1001




TO:           Linford Coleman, Director of Public Housing Hub, Chicago Field Office



FROM:         Heath Wolfe, Regional Inspector General for Audit, Region V

SUBJECT:      Housing Authority of Champaign County
              Citizen Complaint
              Champaign, Illinois

                                      INTRODUCTION

We have completed an audit of the Housing Authority of Champaign County. The audit resulted
from a citizen complaint to our Office. The objectives of our audit were to determine whether
the complainant’s allegations were substantiated and whether HUD’s rules and regulations were
followed.     The complainant’s specific allegations were the Housing Authority: (1)
inappropriately used monies from its Comprehensive Improvement Assistance Grant, Public
Housing Drug Elimination Grant, and Resident Opportunities for Self Sufficiency Grant
Programs; and (2) did not maintain its units in a decent, safe, and sanitary condition.

To accomplish our audit objectives, we reviewed the Housing Authority’s policies and procedures
for the period April 1, 1999 through March 31, 2000. We also reviewed and evaluated the Housing
Authority’s: management controls for safeguarding cash and other monetary assets and segregating
of staff duties; annual financial audit reports and its Board of Commissioners’ minutes for the
period April 1999 through March 2000; and expenditures charged to the Resident Opportunities for
Self Sufficiency Grant, Drug Elimination Grant, and Comprehensive Improvement Assistance
Grant Programs for the period April 1999 through March 2000. In addition, we conducted site
visits to all ten of the Housing Authority’s Public Housing complexes.

We reviewed the Housing Authority’s records and HUD’s records for the Authority. We
interviewed the Housing Authority’s staff, HUD’s staff, and 27 of the Authority’s Public
Housing residents. We performed our on-site audit work between February 2001 and December
2001. We conducted the audit in accordance with Generally Accepted Government Auditing
Standards.




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In accordance with HUD Handbook 2000.06 REV-3, within 60 days please provide us, for each
recommendation without a management decision, 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. Additional status reports are required at 90 days and 120 days after
report issuance for any recommendation without a management decision. Also, please furnish
us copies of any correspondence or directives issued because of the audit.

Should you or your staff have any questions, please have them contact Ronald Huritz, Assistant
Regional Inspector General for Audit, at (312) 353-6236 extension 2675 or me at (312) 353-
7832.

                                        SUMMARY

We found that the Housing Authority charged its HUD-funded Grants (Public Housing, Drug
Elimination, and Comprehensive Improvement Assistance) $27,360 in unallowable expenses.
Of this total, $23,599 was ineligible and $3,761 was unsupported. The ineligible amount
consists of stipends paid to the Housing Authority’s residents who were not eligible to receive
them because they were not officers of the Authority’s Resident Council as required. The
$3,761 in unsupported expenses consists of $2,135 charged to the Drug Elimination Grant and
$1,626 charged to the Comprehensive Improvement Assistance Grant.

                                      BACKGROUND

The Housing Authority was established in 1939 under the laws of the State of Illinois. A
seven member Board of Commissioners governs the Housing Authority. The Chairperson of
the Board is Patricia K. Stebbins. The Authority’s Executive Director is Elawrence Davis.
The Housing Authority’s books and records are located at 205 West Park Avenue,
Champaign, Illinois. The Housing Authority’s maintenance files are located at 201 East
Bradley Avenue, Champaign, Illinois.

As of June 1, 2002, the Housing Authority operated seven HUD programs: (1) Public
Housing Program consisting of 600 units; (2) Section 8 Program consisting of 1,002 units;
(3) Comprehensive Improvement Assistance Grant Program; (4) Public Housing Drug
Elimination Grant Program; (5) Elderly Services Grant Program; (6) Resident Opportunities
for Self Sufficiency Grant Program; and (7) Section 8 New Construction Program consisting
of 50 units.

                                   FINDING
     The Housing Authority Charged HUD For Ineligible And Unsupported Costs

The Housing Authority of Champaign County charged HUD $27,360 in unallowable expenses.
Of this total, $23,599 was ineligible and $3,761 was unsupported. The ineligible amount
consists of stipends paid to Housing Authority residents who were ineligible to receive them.
The unsupported amount consists of undocumented charges of $2,135 and $1,626 to the Drug
Elimination Grant and Comprehensive Improvement Assistance Grant Programs, respectively.




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The Housing Authority did not follow Federal requirements and/or its Travel Policy regarding
the use of HUD funds. As a result, funds were not used in an efficient and effective manner.

                Federal Requirements And The Authority’s Travel Policy

24 CFR Part 964.150(b)(1) permits housing authorities to provide stipends to resident council
officers who serve as volunteers in their public housing units. The housing authority and its
resident council decide the maximum amount of the stipend, not to exceed $200 per month
for each officer.

24 CFR Part 85.20(b)(2) requires housing authorities to maintain accounting records that
adequately identify the application of funds as well as expenditures. 24 CFR Part 85.22(b)
requires that State, local, and Indian tribal governments follow Office of Management and
Budget Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments. 24
CFR Part 85.3 defines a local government to include any public housing agency.

Office of Management and Budget Circular A-87, Attachment A, paragraph C(1)(a), requires
that all costs be necessary and reasonable for proper and efficient performance and
administration of Federal awards. In addition, paragraph C(1)(j) requires that all costs be
adequately documented. Circular A-87 applies to the Public Housing Drug Elimination Grant
and Comprehensive Improvement Assistance Grant Programs.

Section 10.2 of the Housing Authority’s Travel Policy, effective February 26, 1997, requires
that all travel costs except meals, tips, laundry, and cleaning be supported by receipts. No
expense will be reimbursed without receipts.

                      Stipends Were Improperly Paid To Residents

As indicated in the table below, the Housing Authority charged its Public Housing Grant
Program $23,599 in Fiscal Years 1999, 2000, and 2001 for stipends paid to Resident Aides.
Resident Aides are the Housing Authority’s tenants who received monthly stipends for
performing various tasks in and around the Authority’s Public Housing complexes, such as
turning lights on or off and locking and unlocking doors to units and common areas. The
Housing Authority paid the Resident Aides with funds allocated to the Public Housing Grant
Program from the Performance Funding System to support tenant services. None of the
Resident Aides selected by the Housing Authority were resident council officers as required by
24 CFR 964.150(b)(1). Therefore, the Housing Authority did not comply with HUD’s
regulation regarding the payment of resident stipends.

                              1999   2000   2001   Total
                             $6,630 $7,809 $9,160 $23,599

Approximately 20 percent of the total stipends paid were incorrectly calculated. Payments to
nine of the Resident Aides were made two to three times a month, exceeding the $200 per
month/per person maximum allowed by HUD’s regulation. This resulted in some of the
Resident Aides receiving stipends up to $555 per month, or $355 over HUD’s limit of $200.


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The Housing Authority’s staff was not aware of HUD’s regulation regarding the payment of
resident stipends to officers of the Authority’s Resident Council. Instead, the Authority’s
staff repeated the practices of previous employees. The Housing Authority also lacked
supporting documentation to show the services or activities provided by the Resident Aides.

                         The Authority Paid Unsupported Expenses

The Housing Authority lacked adequate supporting documentation to support $2,135 in
expenses charged to its 1998 and 1999 Public Housing Drug Elimination Grants. The
unsupported expenses were for travel costs, purchases of supplies, staff training, and
undefined administrative costs. The Authority provided us with partial documentation that
was not sufficient to identify the exact details of the expenses.

In addition to the unsupported Public Housing Drug Elimination Grant charges, the Housing
Authority could not support $1,626 in expenses charged to its 1998 and 1999 Comprehensive
Improvement Assistance Grants. This amount consisted of $1,519 in hotel expenses and
$107 in transportation expenses. The Housing Authority lacked supporting documentation
for $1,519 in hotel and travel expenses because it did not ensure that its employees
consistently turned in receipts to support travel expenses as required by the Authority’s
February 1997 Travel Policy. As a result, HUD had no assurance that the Housing Authority
paid only reasonable and necessary Drug Elimination and Comprehensive Improvement
Assistance Grant Program expenses. The Housing Authority’s Finance and Accounting
Manager said the Authority needed to tighten up its controls to ensure that documentation
was maintained to support all expenses.

                                    AUDITEE COMMENTS

We provided our draft finding to the Housing Authority’s Executive Director and HUD’s staff
during the audit. We held an exit conference with the Authority’s Executive Director and
Chairperson of the Board of Commissioners on December 13, 2001. The Housing Authority
provided its comments on December 6, 2001. We included the Authority’s comments in
Appendix B of this report. The Housing Authority’s Executive Director and Board Chairperson
were provided with copies of this audit memorandum report.

[Excerpts paraphrased from the Housing Authority of Champaign’s comments on our draft
finding follow. Appendix B, pages 10 to 13, contains the complete text of the comments for
this finding.]

The Board agrees, at least in part, that this finding [pertaining to payment of stipends] is correct.
It appears information provided may have indicated that no resident councils were active. We
understand from this a conclusion was drawn that all of the stipend payments must not be in
compliance with the requirements of 24 CFR 964.150(b), since under that regulation the
resident councils need to identify the residents that are to perform services for which the
payments were being made. We believe it is important to keep in mind that the payments were
made for services actually performed by residents, and the services were specifically to the
benefit of the housing complex and the other residents in each housing complex. While it



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appears that the Authority may not have been current on the regulations with regard to these
payments, none of the payments were fraudulent, made with improper intent, or otherwise
inappropriate in any way. We believe the payments did foster the important purpose of the
resident participation and opportunities programs in that these payments to residents for actual
work performed helped to foster resident involvement in creating a positive living environment.

The Board agrees with the finding [pertaining to unsupported Drug Elimination Grant and
Comprehensive Improvement Assistance Grant expenses] that certain expenses were not
properly documented. It is the understanding of the Board that all of the amounts in question
were in fact appropriate expenses and were paid from the proper funds; however, the proper
supporting documentation for these expenses was not in the Authority’s files.

                    OIG EVALUATION OF AUDITEE COMMENTS

The Housing Authority failed to followed 24 CFR Part 964.150(b) when it paid Resident
Aides who were not officers of the Authority’s Resident Councils. While the Housing
Authority claims the payments were made for services actually performed by the Resident
Aides, the Authority lacked supporting documentation to show the type of services or
activities provided by the Aides. The Authority needs to reimburse its Public Housing
Program for the $23,599 of improper payments to the Resident Aides.

While the Housing Authority claims the $3,761 in unsupported payments were for
appropriate expenses, the Authority is required by 24 CFR Part 85.20 and Office of
Management and Budget Circular A-87 to maintain records of all payments. Therefore, the
Authority needs to provide documentation to support the $3,761 in unsupported payments or
reimburse the appropriate Grant for the applicable amount. We modified our finding to reflect
the supporting documentation provided by the Housing Authority.

                                  RECOMMENDATIONS

We recommend that the Director of Public Housing Hub, Chicago Field Office, ensures that the
Housing Authority of Champaign County:

1A.    Reimburses its Public Housing Program $23,599 from non-Federal funds for stipends
       that were improperly paid to the Resident Aides.

1B.    Establishes procedures and controls to follow HUD’s regulations, Office of
       Management and Budget Circular A-87, and/or the Authority’s Travel Policy regarding
       the payment of resident stipends and maintaining of supporting documentation for
       expenses.

1C.    Provides documentation to support the $3,761 in unsupported expenses or reimburses
       the unsupported amount to the appropriate program from non-Federal funds.




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                               MANAGEMENT CONTROLS

In planning and performing our audit, we considered the management controls of the Housing
Authority of Champaign County 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 to our audit objectives:


·   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 upon our review, we believe the following items are significant weaknesses:

·   Program Operations

The Housing Authority was not operated according to program requirements. Specifically, the
Authority: improperly paid $23,599 in stipends to Resident Aides who were not eligible to
receive them because they were not officers of the Authority’s Resident Council as required;
and failed to maintain documentation to support $3,761 in payments (see Finding).

·      Validity and Reliability of Data

The Housing Authority lacked documentation to support $3,761 in payments from its Public
Housing Drug Elimination and Comprehensive Improvement Assistance Programs (see
Finding).


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·      Compliance with Laws and Regulations

The Housing Authority did not follow HUD’s regulations and/or Office of Management and
Budget Circular A-87 regarding resident stipends and maintaining of supporting documentation
for expenses (see Finding).

·      Safeguarding Resources

The Housing Authority improperly: paid $23,599 in stipends to Resident Aides who were not
eligible to receive them because they were not officers of the Authority’s Resident Council; and
used $3,761 from its Public Housing Drug Elimination and Comprehensive Improvement
Assistance Programs without supporting documentation (see Finding).




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                           FOLLOW-UP ON PRIOR AUDITS

HUD’s Office of Inspector General issued a prior audit report (#94-CH-202-1012) of the
Housing Authority of Champaign County on January 11, 1994. The audit report included
eight findings. The recommendations for the eight findings are all closed. None of the eight
findings are repeated in this audit memorandum report.

The latest Independent Auditor’s Report for the Housing Authority covered the fiscal year
ended March 31, 2001. The Report contained no findings.




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                                                                               Appendix A

                       SCHEDULE OF QUESTIONED COSTS



Recommendation                     Type of Questioned Cost
   Number                   Ineligible 1/         Unsupported 2/

      1A                    $23,599
      1C                                              $3,761
     Totals                 $23,599                   $3,761


1/    Ineligible costs are costs charged to a HUD-financed or HUD-insured program or
      activity that the auditor believes are not allowable by law, contract or Federal, State
      or local policies or regulations.

2/    Unsupported costs are costs charged to a HUD-financed or HUD-insured program or
      activity and eligibility cannot be determined at the time of audit. The costs are not
      supported by adequate documentation or there is a need for a legal or administrative
      determination on the eligibility of the costs. Unsupported costs require a future
      decision by HUD program officials. This decision, in addition to obtaining
      supporting documentation, might involve a legal interpretation or clarification of
      Departmental policies and procedures.




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                                                                                   Appendix B

                                  AUDITEE COMMENTS

                                      December 6, 2001



VIA FEDERAL EXPRESS AND
ELECTRONIC DELIVERY ON DISKETTE


Mr. Ronald F. Huritz
Assistant District Inspector General for Audit
Department of Housing and Urban Development
Office of Inspector General
77 West Jackson Boulevard, Room 2646
Chicago, IL 60604


Re: Draft Audit Finding with regard to the Housing Authority of Champaign County

Dear Mr. Huritz:

        The Board of Commissions of the Housing Authority of Champaign County (the
“Authority”) has met to review the Draft Audit Finding forwarded with your letter of
November 13, 2001. We submit this letter as the response of the Authority to each of the two
specific issues and four specific recommendations proposed in the Draft Audit Finding. We
have addressed each of these by separate paragraphs below.

        First, we would like to take a moment to thank the Office of the Inspector General
and Mr. Yama Burkley, the auditor in charge, for the courtesies shown to this Authority
during the more than five months Mr. Burkley spent in what we understand to be a very
thorough review of the practices and procedures at this Authority. Mr. Burkley and other
members of your staff were very professional and courteous at all times. We trust
representatives of the Authority were equally courteous and professional and responded
promptly and appropriately to all requests from your staff.

Response to Issues

Issue #1: “Some stipends were improperly paid to residents”

       The Board agrees, at least in part, that this finding is correct. It appears information
provided to your staff may have indicated that no resident councils were active. We
understand from this a conclusion was drawn that all of the stipend payments must not be in
compliance with the requirements of 24 CFR 964.150(b), since under that regulation the



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resident councils need to identify the residents that are to perform services for which the
payments were being made.

        You may be aware that although the Authority can encourage the formation and
continuation of resident councils, the residents must themselves take responsibility for the
operations of the resident councils. Despite encouragement by the Authority, resident
councils that have been formed in the past have not been able to be continued, and although
most of the Authority’s housing communities have had resident councils at one time or
another, they have not remained in continuous operation for each housing communities. The
Board agrees that some of the complexes with respect to which these payments were being
made did not have active resident councils at the time of the payments. The Board is not
clear, however, that the individuals who were receiving these payments had not previously
been approved for these positions by a then-active resident council and simply continued
performing them after the resident council became inactive.

        We also want to address the issue raised that some of these individuals received more
than the maximum amount allowed per month. We understand that this most likely arose
because some of the residents performing these services decided they did not want to
continue with those responsibilities. We understand few residents were willing to take on
these responsibilities, but some residents who were already performing services were willing
to pick up the additional responsibilities of the residents who did not want to continue. We
believe the overpayments arose simply as a result of trying to allow these services to
continue to be performed by residents.

        In each of the above situations, we believe it is important to keep in mind that the
payments were made for services actually performed by residents, and the services were
specifically to the benefit of the housing complex and the other residents in each housing
complex. While it appears that the Authority may not have been current on the regulations
with regard to these payments, none of the payments were fraudulent, made with improper
intent, or otherwise inappropriate any way. Although the payments were not made in full
compliance with the cited regulations that we were able to review, we believe the payments
did foster the important purpose of the resident participation and opportunities programs as
noted in 24 CFR 964.1, in that these payments to residents for actual work performed helped
to foster resident involvement in creating a positive living environment and in actively
participating in the operation of the Authority.

Issue #2: “Unsupported drug elimination grant and comprehensive grant expenses”

       The Board agrees with the finding under this issue that certain expenses were not
properly documented. It is the understanding of this Board that all of the amounts in
question were in fact appropriate expenses and were paid from the proper funds, however,
the proper supporting documentation for these expenses was not in the Authority’s files.

Response to Recommendations




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Recommendation 1A: “Repays HUD $23,599 from non-Federal funds for the stipends
that were paid to ineligible tenants”

       The Board respectfully requests that this recommendation not be implemented. This
Board does not sanction payments that are not in compliance with the regulations applicable
to programs in which it participates; however, the Board strongly believes that these funds,
although perhaps not spent in compliance with the requirements of the relevant regulations
and policies, were in fact expended for, and helped to advance, the important purposes of the
Authority’s Tenant Participation Program. As noted above, these funds were paid to
residents for work that was actually performed and that did in fact benefit the housing
complex where the work was performed and all the residents of those complexes. Although
the Authority will, as noted below, take action to see that any issues of compliance are
promptly addressed, the Board requests that the recommendation for repayment of $23,599
from non-Federal funds be waived.

Recommendation 1B: “Establishes procedures to ensure compliance with regulations
and Housing Authority policies regarding the payment of stipends to residents”

       The Authority agrees and has already taken steps to accomplish this. All active
resident councils have been contacted to coordinate an item on the agenda for the next
meeting to address these issues. The Board has directed the appropriate Authority staff
members to coordinate with each resident council to help assure that the appropriate
procedures are established and maintained so that payment of the stipends to residents will be
in compliance.

Recommendation 1C: “Provides HUD with documentation to support $8,653 in
unsupported expenses, or repays the unsupported amount to HUD from non-Federal
funds”

        The Authority agrees with this recommendation. We would note that steps are
currently underway to obtain the necessary documentation with regard to each of these
expenses. The Authority requests an additional 30 days to complete the gathering of this
documentation and will then forward it to Mr. Burkley. We believe the Authority should be
able to properly document substantially all of these expenses and that minimal, if any,
reimbursement should be required.

Recommendation 1D: “Establishes procedures to ensure compliance with Federal
requirements and its Tenant Participation Procurement and Travel policies regarding
support for reimbursable expenses”

       The Authority agrees with this recommendation and has already implemented it.
                                          _______

       In summary, although this Board is never pleased to find that the Authority is not in
compliance with any applicable regulation or policy, we would like to note that after the
extensive on-site audit that was conducted, only one audit finding was presented. This



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Authority operates over 600 units in ten housing communities in three cities in Champaign
County, Illinois, with a staff of approximately 48 employees and an annual budget in excess
of $10,000,000. We believe that our staff has been working diligently to assure to the fullest
extent possible that this Authority is conducting its business appropriately. We regret the
lack of information on the part of this Authority with regard to Issue #1, but stress again that
we believe the funds that were paid did advance the purposes of the policy even though not
in compliance with the procedures.

       We thank you for the opportunity to respond to the issues in the Draft Audit Finding
and note that this Board is willing to discuss any of these matters with an appropriate
member of your agency or with the appropriate individual at the Department of Housing and
Urban Development at any time. Please feel free to contact our chairperson, Patricia
Stebbins, at 217-367-1536. Thank you for your consideration.

                                                      Very truly yours,


                                                              /signed/
                                                      Patricia Stebbins, Chairperson, Housing
                                                      Authority of Champaign County




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                                                                              Appendix C

                         DISTRIBUTION OUTSIDE OF HUD

The Honorable Joseph Lieberman, Chairman, Committee on Government Affairs, 706
        Hart Senate Office Building., United States Senate, Washington, DC 20510
The Honorable Fred Thompson, Ranking Member, Committee on Governmental Affairs,
        340 Dirksen Senate Office Building, United States Senate, Washington, DC 20510
The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185
        Rayburn Building, House of Representatives, Washington, DC 20515
The Honorable Henry A. Waxman, Ranking Member, Committee on Government
        Reform, 2204 Rayburn Building., House of Representatives, Washington, DC 20515
Andy Cochran, Committee on Financial Services, 2129 Rayburn House Office Building,
        United States House of Representatives, Washington DC 20515
Clinton C. Jones, Senior Counsel, Committee on Financial Services, B303 Rayburn Building,
        United States House of Representatives, Washington DC 20515
Sharon Pinkerton, Senior Advisor, Subcommittee on Criminal Justice, Drug Policy &
        Human Resources, B373 Rayburn House Office Building, United States Housing of
        Representatives, Washington, DC 20515
Stanley Czerwinski, Director, Housing and Telecommunications Issues, United States
        General Accounting Office, 441 G Street, NW, Room 2T23, Washington, DC 20548
Steve Redburn, Chief of Housing Branch, Office of Management and Budget, 725 17th
        Street, NW, Room 9226, New Executive Office Building, Washington, DC 20503
Linda Halliday (52P), Department of Veterans Affairs, Office of Inspector General, 810
        Vermont Avenue, NW, Washington, DC 20420
William Withrow (52KC), Department of Veterans Affairs, Office of Inspector General
        Audit Operations Division, 1100 Main, Room 1330, Kansas City, Missouri 64105-
        2112
Kay Gibbs, Committee on Financial Services, 2129 Rayburn House Office Building,
        United States House of Representatives, Washington DC 20515
George Reeb, Assistant Inspector General for Health Care Financing Audits
Elawrence Davis, Executive Director of the Housing Authority of Champaign County
Patricia K. Stebbins, Chairperson of the Board of Commissioners of the Housing Authority
        of Champaign County




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