AUDIT REPORT HOUSING CHOICE VOUCHER SUBSIDY STANDARDS HOUSING AUTHORITY OF THE CITY OF HOUSTON HOUSTON, TEXAS 2004-FW-1010 September 29, 2004 OFFICE OF AUDIT, REGION 6 FORT WORTH, TEXAS Issue Date September 29, 2004 Audit Case Number 2004-FW-1010 TO: Dan Rodriguez Program Center Coordinator, Office of Public Housing, 6EPH FROM: D. Michael Beard Regional Inspector General for Audit, 6AGA SUBJECT: Housing Choice Voucher Subsidy Standards Housing Authority of the City of Houston Houston, Texas We audited the Housing Authority of the City of Houston (the Authority). This audit reviewed the administration of the Section 8 Program concerning assistance payments to families housed in larger units than the Authority’s policy allowed. Additional audits concerning the Authority’s Section 8 Program including: (1) housing quality standards; (2) calculation of housing assistance payments; and (3) assistance payment databases are underway or planned. Our report contains one finding with recommendations requiring action by your office. The audit objective was to determine whether the Authority used its Section 8 funds to pay housing assistance for tenants who are housed in a larger unit than the Authority’s policy allows. In accordance with U.S. Department of Housing and Urban Development Handbook 2000.06, REV-3, within 60 days, please provide us for each recommendation without management decisions, 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 the report is issued 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 contact Theresa Carroll, Assistant Regional Inspector General for Audit, at (817) 978-9309. Management Memorandum THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page ii Executive Summary As part of the Office of Inspector General’s Annual Audit Plan, we audited the Housing Authority of the City of Houston (the Authority). The objective of this audit was to determine whether the Authority used its Section 8 funds to pay housing assistance for tenants who are housed in larger units than the Authority’s policy allows. Additional audits of the Authority’s Section 8 Program are underway. The Authority paid Section 8 Housing Choice Voucher The Authority paid funds for tenants to live in larger units than the Authority’s excessive Section 8 policy allowed. Testing showed the Authority overpaid at assistance. least $797,280 to improperly house at least 352 Section 8 tenants between January 2002 and May 2004. Statistical testing identified $172,193 in actual ineligible overpayments and a minimum of $625,087 in projected overpayments. In addition, the Authority could overpay more than $3.2 million over the next 3.71 years if it does not implement controls to stop the overpayments. The Authority made the overpayments because its Contractor chose not to follow the Authority’s policy to avoid increasing its already backlogged workload. The Authority’s monitoring, which should have detected and prevented the improper payments, was not sufficient to do so. We recommend that the U.S. Department of Housing and Recommendations. Urban Development (HUD) require the Authority to comply with the unit size limitations in its Administrative Plan. We also recommend that HUD require the Authority to: • Repay $172,193 in identified Section 8 overpayments; • Review other identified tenants potentially living in units larger than the Authority’s policy allows and repay any ineligible Section 8 assistance, which we project to be at least $625,087; and • Implement controls to avoid future estimated overpayments of $3.2 million over the next 3.7 years. 1 According to a HUD Office of Policy Development and Research report, dated January 2003, the average Section 8 tenant in Houston resides in an assisted unit for 3.7 years. Page iii 2004-FW-1010 Executive Summary THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page iv Table of Contents Management Memorandum i Executive Summary iii Introduction 1 Finding The Authority Paid for Tenants to Reside in Larger Units 5 than Allowed Internal Controls 9 Appendices A. Schedule of Questioned Costs and Funds to be Put to 11 Better Use B. Auditee Comments 13 C. Sample Selection, Testing Methodology, and Test Results 19 Page v 2004-FW-1010 Table of Contents THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page vi Introduction The City of Houston established the Housing Authority of the City of Houston (the Authority) in 1938. The Mayor appoints a five-member Board of Commissioners (Board) to govern the Authority. The Board hires an Executive Director to manage the Authority’s day-to-day operations. The Authority keeps its records at its central office at 2640 Fountainview, Houston, Texas. The Authority has operated its Section 8 Rental Assistance Program since 1975. HUD executed the Authority’s first Section 8 contract in June 1975 to serve 1,619 families. In June 1985, HUD executed the Authority’s first Housing Voucher contract to serve an additional 91 families. In 2000, HUD combined the Section 8 and Housing Voucher Programs to create the Housing Choice Voucher Program. During the period January 2002 through May 2004, the Authority administered more than 16,000 Housing Choice Vouchers, including vouchers that it terminated during the period. From 2002 to 2003, HUD paid the Authority $185 million to fund the Housing Choice Voucher Program, including $14.5 million for the Authority’s administrative expenses related to the program. During 2001, HUD designated the Authority “troubled” The Authority hired a and gave it a very low Section 8 Management Assessment contractor to improve its Program score. The Authority contracted with Quadel performance. Consulting (Contractor) in December 2001 to manage and improve its Section 8 Program performance. The Contractor formed a subsidiary, Houston Housing Assistance Partnership, to perform the contract work. The Authority paid the Contractor 85 percent of the administrative fees that HUD awarded the Authority to operate the Section 8 program. The Contractor did improve the Authority’s score out of the “troubled” category. Even though the Authority hired a contractor to manage and operate its Section 8 Program, it is ultimately responsible to HUD for program operations and for any errors. Our objective was to determine whether the Authority used Audit Objective its Section 8 funds to pay housing assistance for tenants who were housed in larger units than the Authority’s policy allowed. To achieve the objective, we: Audit Scope and Methodology • Reviewed HUD’s and the Authority’s regulations; • Reviewed tenant data maintained in HUD’s Public and Indian Housing Information Center database; Page 1 2004-FW-1010 Introduction • Reviewed a statistical sample of inappropriately housed tenant files maintained by the Contractor at the Authority’s central office; • Interviewed HUD, Authority, and Contractor staff as necessary; and • Recalculated assistance payments to determine how much the Authority overpaid when it did not use appropriate unit size or correct payment standards. Appendix C contains detailed information regarding our Sample Selection and sample selection, testing methodology, and test results. Testing Methodology By comparing Multifamily Tenant Characteristics System (MTCS)2 data to the subsidy standards in the Authority’s Administrative Plan, we determined that the Authority paid assistance for 1,824 out of 16,065 tenants to occupy larger and smaller units than the Authority’s policy allowed during the period January 2002 through May 2004. We identified the 1,824 tenants by comparing their family sizes and unit sizes to the subsidy limits in the Authority’s Administrative Plan, below: Minimum # Maximum # Voucher Persons in Persons in Size Household Household 0 BR 1 1 1 BR 1 2 2 BR 2 4 3 BR 3 6 4 BR 4 8 5 BR 5 10 6 BR 6 12 By performing additional analyses on the data in the MTCS database for these 1,824 families, we determined that the Authority may have overpaid assistance for 501 of the tenants because: • The tenants possessed a Section 8 Housing Choice Voucher with more bedrooms than their family size allowed and 2 Multifamily Tenant Characteristics System is a HUD database containing demographic data on Section 8 tenants. 2004-FW-1010 Page 2 Introduction • The Authority’s actual assistance payment exceeded its subsidy payment standards for the appropriately sized unit, based on the tenant’s family size. We selected a statistical sample3 of 98 of the 501 tenants to confirm the Authority was overpaying assistance for tenants housed in larger units than its policy allows. We requested and reviewed the Authority’s tenant files for any evidence that these 98 tenants warranted larger units. If we found that the tenants did not warrant larger units, we recalculated the assistance payments for those tenants using the correct bedroom size and compared it with the Authority’s calculations. When we conducted the testing, we accepted and did not re-verify the Authority’s housing assistance calculations for income, deductions, and utility allowances. If the Authority’s total rental assistance calculations exceeded our calculations, we considered the excess funds to be overpayments. Additional instances of tenants in larger units than allowed by Additional instances of the Authority’s policy may exist. Our testing may not have tenants in larger units than detected all improperly housed tenants because we only allowed may exist. tested those family sizes that obviously fell outside the range created by the maximum and minimum size limits in the Authority’s Administrative Plan. We did not attempt to test for tenants that could have fallen inside the maximum and minimum size limits based on their family composition. For example, the subsidy standards allow a two-person household to have a one- or two-bedroom unit. However, if the two- person household composition is a mother and a child under 5 years old, the Administrative Plan requires the Authority to issue a one-bedroom voucher.4 We performed audit work from March through July 2004 at the Authority’s central office at 2640 Fountainview, Houston, Texas. The audit covered the period January 1, 2002, through May 24, 2004. We extended the review, when appropriate, to include other periods. We conducted the audit in accordance with generally accepted government auditing standards. 3 We used EZ Quant statistical sampling software to select a simple random sample with a 90 percent confidence level and a 10 percent precision range. 4 The Authority’s Administrative Plan, January 1, 2004, revision, page 23. Page 3 2004-FW-1010 Introduction THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page 4 Finding 1 The Authority Paid for Tenants to Reside in Larger Units Than Allowed The Authority paid Section 8 Housing Choice Voucher funds for tenants to live in larger units than its policy allowed. Consequently, the Authority overpaid at least $797,280 to house its Section 8 tenants between January 2002 and May 2004. Statistical testing identified $172,193 in actual ineligible overpayments and a minimum of $625,087 in projected overpayments. In addition, the Authority could overpay more than $3.2 million over the next 3.75 years if it does not implement controls to stop the overpayments. The Authority made the overpayments because its Contractor chose not to follow the Authority’s policy to avoid increasing its already backlogged workload. In addition, the Authority's monitoring, which should have detected and prevented the improper payments, was not sufficient to do so. HUD requires the Authority to establish subsidy standards to HUD and Authority set how much rental assistance it will pay for each unit size Requirements. based on the number of bedrooms in the unit.6 HUD also requires the Authority to apply the subsidy standards consistently for all tenant families of like size and composition.7. The Authority established its subsidy standards in its Administrative Plan. The Administrative Plan requires the Authority to: Issue the minimum subsidy standard available to adequately serve a family8 and Upgrade or downgrade a family’s voucher as appropriate.9 The Authority’s The Authority’s Contractor determines the number of Contractor issues persons in a tenant’s family applying for a voucher. It vouchers to tenants. consults the Authority’s subsidy standard table in its Administrative Plan to determine the appropriate unit size. Once the Contractor makes the determination, it issues a Housing Choice Voucher to the tenant for the appropriate unit size. The voucher allows the tenant to rent any size unit. However, the Authority’s subsidy standards limit 5 According to a HUD Office of Policy Development and Research report, dated January 2003, the average Section 8 tenant in Houston resides in an assisted unit for 3.7 years. 6 Section 8 Program 24 Code of Federal Regulations 982.402, paragraph (a). 7 Section 8 Program 24 Code of Federal Regulations 982.402, paragraph (b)(3). 8 Administrative Plan, January 1, 2004, revision, page 23. 9 Administrative Plan, January 1, 2004, revision, page 37. Page 5 2004-FW-1010 Finding 1 rental assistance to the number of bedrooms on the voucher. Testing showed the Authority improperly housed 76 of the 98 statistically sampled tenants in larger units than its policy allowed. Further, the Authority overpaid $172,193 in Section 8 Housing Choice Voucher assistance for these 76 tenants. When projected to the population of 501 tenants, statistical theory shows that the Authority has overpaid at least $625,087 on other tenants improperly housed in units that are larger than allowed. Further, if the Authority continues to pay for tenants to lease larger units than they are allowed, it could overpay more than $3.2 million in assistance over the next 3.7 years. Although the Authority initially issued the correct voucher The Authority overpaid size for most of the tenants tested, its Contractor failed to because the Contractor downgrade the vouchers as the tenant’s family sizes changed. did not downgrade In some cases (22%), the Contractor justifiably issued larger vouchers. units to tenants with exceptional medical circumstances. According to one of the Contractor’s managers, the Contractor did not downgrade the vouchers because it chose not to follow the Authority’s policy to avoid increasing its already backlogged workload. The Authority’s monitoring of the Contractor’s performance did not detect the Contractor’s decision to violate the Authority’s policy. The Authority’s Director of Regulatory Compliance and The Authority agreed and Intergovernmental Affairs agreed that the Authority housed expects to complete the identified tenants in units larger than policy allowed. He corrections by October stated that the Authority has taken steps to correct the 76 2004. erroneous files and anticipates completion by the end of October 2004. Auditee Comments The Authority agreed the problems discussed in the finding existed and are in immediate need of correction. The Authority concurred that it overpaid $172,193 and stated it is having its Contractor review and take corrective action on the 76 participants. The Authority indicated it developed a plan to review all of its participant files to identify any that are over-housed. Further, the Authority indicated it is performing a comprehensive review of the remaining 403 files out of the 501 identified as potentially 2004-FW-1010 Page 6 Finding 1 over-housed by OIG. The Authority expects this review to be completed in 30 days. In addition, the Authority agreed to relocate or take other administrative action to ensure that housing is appropriately based on the number of persons in a household. The Authority also stated that it will take operational and administrative control of its Section 8 Programs from its Contractor, effective October 20, 2004. Finally, the Authority indicated it would not incur future estimated overpayments of $3.2 million because it is taking corrective actions to prevent such a problem. OIG Evaluation of We appreciate the Authority agrees a problem exists and Auditee Comments has detailed actions to correct the problems. The Authority has outlined corrective actions including a comprehensive review of all potentially over-housed tenant files within the next 30 days. Then, the Authority will review all of its remaining Section 8 files. Further, the Authority indicated it would assume responsibility for the Section 8 Program from its Contractor. If followed, these steps should be sufficient to correct and prevent the Authority from paying assistance to tenants who are living in a larger unit than the Authority’s policy allows. We recommend HUD require the Authority to: Recommendations 1A. Comply with the unit size limitations in the Administrative Plan. 1B. Repay $172,193 in identified Section 8 overpayments. 1C. Review other identified tenants potentially living in units larger than the Authority’s policy allows and repay any ineligible Section 8 assistance, which we project to be at least $625,087. 1D. Implement controls to avoid future estimated overpayments of $3,232,953 over the next 4 years. Page 7 2004-FW-1010 Finding 1 THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page 8 Internal 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 that the following management controls were Relevant Internal Controls relevant to our audit objectives: • Management’s assurance that the Contractor complies with the terms of the Administrative Plan and • Contractor’s quality control system, through which it self-assesses its performance and provides feedback via training to its employees. We assessed 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 identified two significant Significant Weaknesses weaknesses: 1. The Authority did not monitor the Contractor sufficiently to ensure that it followed the Authority’s policy. 2. The Authority’s Contractor intentionally circumvented the controls established to prevent the Authority from overpaying Section 8 Housing Choice Vouchers. Page 9 2004-FW-1010 Internal Controls THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page 10 Appendix A Schedule of Questioned Costs and Funds to be Put to Better Use Recommendation Ineligible 1 Unsupported 2 Funds Put to Better Use3 1B $172,193 1C $625,087 1D $3,232,953 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 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. 3 “Funds put to better use” are costs that will not be expended in the future if our recommendations are implemented, including costs not incurred, de-obligation of funds, withdrawal of interest, reductions in outlays, avoidance of unnecessary expenditures, loans and guarantees not made, and other savings. Page 11 2004-FW-1010 Appendix A THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page 12 Appendix B Auditee Comments Page 13 2004-FW-1010 Appendix B 2004-FW-1010 Page 14 Appendix B Page 15 2004-FW-1010 Appendix B 2004-FW-1010 Page 16 Appendix B Page 17 2004-FW-1010 Appendix B THIS PAGE LEFT BLANK INTENTIONALLY 2004-FW-1010 Page 18 Appendix C Sample Selection, Testing Methodology, and Test Results SAMPLE SELECTION: We found records for 16,065 tenants in the MTCS database for the period January 2002 through May 2004. The records included those tenants that the Housing Authority terminated from the program during the period. We performed several sorts on the data in the records to determine which units the Authority may have over-subsidized based on tenant family sizes. We sorted the listing by voucher size and number of persons in the household. We compared the voucher size and number of household members to the unit size limits in the Authority’s Administrative Plan and found 1,824 tenants whose voucher sizes were greater than or less than the size limits. We sorted the 1,824 tenants by number of household members and compared the number of household members to the number of bedrooms on the 1,824 tenants’ vouchers. We identified 1,088 of the 1,824 tenants whose voucher sizes exceeded the number of family members. We then compared the number of family members in each household to the actual number of bedrooms in the tenant’s home and identified 891 tenants who had excessive voucher sizes and lived in larger units than their number of family members warranted. We then compared each tenant’s rent to the appropriate payment standard for the tenant’s family size and determined that the rent exceeded the payment standard for 501 of the 891 tenants. These are the tenants for whom the Authority may have overpaid housing assistance because the Authority subsidized the tenants’ residence in larger units than the Authority’s policy allows. However, there are some allowable exceptions according to the Administrative Plan. Therefore, we selected a representative statistical sample of the 501 tenants and tested them. We used EZ QUANT statistical software to select our sample. We defined the unit to be sampled as a tenant file in which the Authority paid to house a tenant in a unit larger than the Authority’s Administrative Plan allowed. We determined that there were 501 such tenants in the universe. We desired a 90 percent confidence level that the results of the statistical testing would be within a 10 percent precision range. Based on the size of the universe (501), a presumed error rate of 10 percent, a precision rate of 10 percent, and a desired confidence level of 90 percent, the EZ Quant software selected 98 random samples for testing. TESTING METHODOLOGY: We defined an error as any tenant file in which the Authority housed a tenant in a unit and paid more than the maximum payment allowed by the Authority’s Administrative Plan for a correct unit size. Page 19 2004-FW-1010 Appendix C In order to test the samples, we reviewed the 98 tenant files to determine whether the tenant warranted a larger unit due to medical needs or some other exception listed in the Administrative Plan. If there was no documented exception in the tenant file, we recalculated the assistance payments using the correct payment standards in the Administrative Plan. For purposes of the recalculations, we accepted and did not re-verify the Authority’s housing assistance calculations for income, deductions, and utility allowances. We used the EZ Quant software to project the test results onto the population. TEST RESULTS: We found that the Contractor had incorrectly calculated the assistance payments for 76 of the 98 tenants because it used incorrect payment standards. As a result, the Authority overpaid $172,193 to over house the 76 tenants. When we used EZ Quant to project the results to the population, we found that the Authority over housed between 352 and 419 of the 501 tenant families, and that the Authority overpaid between $797,280 and $949,035 to over house them. We determined that the Authority overpaid $14,244 for the 98 sample tenants during May 2004. Each of the 98 tenants will be in a single assisted unit in the City of Houston for an average of 3.7 years, therefore, the Authority would overpay $632,433 for the 98 tenants over their average stay in their current units ($14,244 overpaid/month X 12 months/year X 3.7 years = $632,433). That equates to $6,453 per tenant over 3.7 years ($632,433/98 tenants = $6,453/tenant). Therefore, if the Authority does not correct the over housing, we project that it could overpay $3,232,953 over the next 3.7 years ($6,453/tenant X 501 tenants = $3,232,953). We included the test results of the 98 samples below: Family Members Bedrooms Voucher in Bedrooms on Overpayment Overpayment Overpaid # Number Household in unit Voucher Start Date End Date Amount 1 13812 2 3 3 Oct-02 May-04 $ 5,468 2 19755 1 2 2 May-02 May-04 2,849 3 50271 1 2 2 Mar-04 May-04 168 4 23582 3 4 4 Feb-03 May-04 2,174 5 79735 1 2 3 Apr-04 May-04 344 6 06293 2 3 4 Aug-03 May-04 180 7 03019 1 2 2 Nov-02 May-04 3,046 8 18749 2 4 3 Feb-02 May-04 8,368 9 18913 2 3 3 Aug-02 May-04 3,740 10 19304 1 2 2 0 11 22220 2 3 3 Mar-04 May-04 648 12 79868 1 2 2 Aug-03 May-04 170 2004-FW-1010 Page 20 Appendix C 13 00542 2 3 3 May-03 May-04 2,156 14 17191 1 2 2 Jun-03 May-04 1,068 15 03941 1 3 3 Oct-02 May-04 4,700 16 45419 1 2 2 0 17 52275 1 2 3 0 18 75092 1 2 2 0 19 52546 2 4 3 0 20 16482 2 3 3 0 21 52744 1 2 2 0 22 36589 2 3 3 Dec-03 May-04 762 23 00410 1 3 3 0 24 35624 1 2 2 0 25 05970 2 4 3 Dec-02 May-04 4,302 26 53351 1 2 2 Jan-04 May-04 595 27 22170 2 3 3 Aug-02 May-04 3,726 28 54465 2 4 3 Aug-03 May-04 2,070 29 47099 1 2 2 Nov-03 May-04 1,204 30 29341 1 2 2 Sep-02 May-04 2,417 31 02202 1 3 3 Jan-03 May-04 6,500 32 14356 1 2 2 0 33 86508 1 2 2 Jun-03 Dec-03 1,183 34 56029 1 3 3 Apr-03 May-04 5,754 35 17966 2 3 3 Sep-03 May-04 1,179 36 51699 2 3 3 0 37 89112 2 3 3 Nov-03 May-04 567 38 20683 1 2 2 0 39 58869 2 3 3 0 40 08394 2 3 3 Sep-02 May-04 2,844 41 45406 2 3 3 Mar-04 May-04 396 42 37029 2 3 3 Feb-04 May-04 632 43 79919 1 2 3 0 44 18247 2 3 3 Oct-03 May-04 1,968 45 04929 1 3 2 Oct-02 May-04 3,014 46 18189 1 2 3 Jan-04 May-04 360 47 25812 2 3 3 Dec-03 May-04 1,394 48 40648 1 2 2 0 49 20521 1 2 2 Feb-04 May-04 680 50 27559 1 3 3 Jun-03 May-04 2,640 51 15122 1 3 2 0 52 00017 1 2 2 Jun-03 May-04 924 53 01308 1 3 3 Jan-03 May-04 2,228 54 04005 1 2 2 Feb-03 May-04 1,032 55 26245 2 3 3 Dec-02 May-04 1,992 56 43139 1 2 2 Aug-02 May-04 2,058 57 23585 2 4 3 Dec-02 May-04 4,602 Page 21 2004-FW-1010 Appendix C 58 48987 2 4 3 Apr-03 May-04 4,140 59 19225 2 3 3 Feb-04 May-04 496 60 16991 1 2 2 Dec-02 May-04 2,224 61 71766 1 3 3 0 62 17395 1 2 2 0 63 32521 1 3 2 Jun-02 May-04 2,633 64 18038 2 3 3 Nov-02 Apr-03 1,056 65 56730 2 4 3 Aug-02 May-04 6,074 66 36799 1 3 3 Jun-03 May-04 4,470 67 03515 1 2 2 Sep-02 Aug-03 1,932 68 20669 2 3 3 May-03 May-04 2,291 69 37158 1 2 2 Aug-03 May-04 490 70 02067 2 3 3 Sep-02 May-04 3,788 71 40368 1 2 2 Sep-02 May-04 1,421 72 22296 2 3 3 Jul-02 Jan-04 3,033 73 00175 1 3 3 Jan-04 May-04 775 74 36862 1 2 2 0 75 04953 2 3 3 Dec-02 May-04 3,582 76 07007 1 3 3 Aug-02 May-04 2,048 77 69948 1 2 2 0 78 21999 1 3 3 Dec-02 Apr-03 1,250 79 17124 1 2 2 Jul-03 May-04 759 80 43762 2 3 3 May-04 May-04 243 81 21874 2 3 3 Dec-03 May-04 936 82 25983 2 3 3 Mar-03 May-04 459 83 06850 1 2 2 Oct-02 May-04 2,948 84 38526 1 2 2 May-04 May-04 159 85 34987 2 3 3 Feb-03 May-04 3,036 86 37509 1 2 2 0 87 75153 1 2 2 Jul-03 Jun-03 936 88 38837 1 2 2 Jul-02 May-04 2,632 89 09895 2 3 3 Oct-02 May-04 3,261 90 23882 2 3 3 Aug-03 May-04 2,938 91 68401 1 2 2 Sep-03 May-04 126 92 68655 1 4 4 Nov-02 May-04 7,045 93 17486 1 3 3 Jan-03 May-04 3,809 94 39308 1 3 3 Jan-04 May-04 2,305 95 73410 2 3 3 Mar-04 May-04 729 96 18563 1 3 3 Nov-03 May-04 3,059 97 89491 1 2 2 0 98 76212 1 2 2 May-02 Apr-04 3,008 Total Overpayments $172,193 2004-FW-1010 Page 22
Housing Choice Voucher Subsidy Standards, Housing Authority of the City of Houston, Houston, TX
Published by the Department of Housing and Urban Development, Office of Inspector General on 2004-09-29.
Below is a raw (and likely hideous) rendition of the original report. (PDF)