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
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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
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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
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Table of Contents
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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.
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Introduction
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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
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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
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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
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2004-FW-1010 Page 12
Appendix B
Auditee Comments
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Appendix B
2004-FW-1010 Page 14
Appendix B
Page 15 2004-FW-1010
Appendix B
2004-FW-1010 Page 16
Appendix B
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Appendix B
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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)