Telephone: (213) 894-8016 http:www.hud.gov/offices/oig/ Fax: (213) 894-8115 Issue Date: November 4, 2004 Audit Case Number: 2005-LA-1801 MEMORANDUM FOR: Janet L. Browder, Director, HUD’s Office of Multifamily Housing, 9AHMLA FROM: Joan S. Hobbs, Regional Inspector General for Audit, 9DGA SUBJECT: The Carmichael Rehabilitation Center Federal Housing Administration Project Number 136-43061 Carmichael, California INTRODUCTION We have completed an audit of the Carmichael Rehabilitation Center, a Section 232 Nursing Home. Our review was initiated as part of a nationwide review of the Department of Housing and Urban Development’s (HUD) Section 232 program. The objective of this review was to determine if the owner of the Carmichael Convalescent Center complied with the terms of the Regulatory Agreement with HUD. We found that the owner did not follow HUD requirements and mismanaged the project’s operations by defaulting on the project’s mortgage and through ineligible disbursements of the project funds. The audit was performed in accordance with generally accepted government auditing standards. Audit work was performed between December 2003 and July 2004, and generally covered the period of January 1997 through September 2002, which was expanded as necessary. In conducting the audit, we reviewed records provided by the owner and interviewed appropriate members of the owner’s staff and management. We also interviewed a partner from the project’s financial audit firm, and reviewed their audit working papers. In addition, we reviewed HUD monitoring files, spoke to HUD officials, and reviewed the applicable HUD requirements. As required by HUD Handbook 2000.6 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. Also, please furnish us copies of any correspondence or directives issued because of the audit. Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 Should you or your staff have any questions, please contact me at (213) 534-2470, or Clyde Granderson, Assistant Regional Inspector General for Audit, at (415) 489-6692. SUMMARY We identified violations of the Carmichael Rehabilitation Center’s Regulatory Agreement and other HUD requirements. This included the owner, Sun Healthcare, incorporating the project in its petition for bankruptcy and subsequently defaulting on the project’s mortgage. In addition, during the time period leading up to and during the default, the owner disbursed $3,769,290 in project funds through ineligible cash distributions and expenses. These activities resulted in increased risk to HUD, the assignment of the mortgage note to HUD, and HUD’s resulting loss of $323,925 on the sale of the note. BACKGROUND Section 232 of the National Housing Act authorized a mortgage insurance program for residential care facilities (12 U.S.C. 1715w). HUD insured a $4.9 million mortgage under the Federal Housing Administration Section 232 program, to establish the Carmichael Rehabilitation Center in November 1992. The project has a 126-bed capacity and is located in the city of Carmichael, California. The Project Funding Corporation was the holder of the mortgage note. The owner of Carmichael is Sun Healthcare Group, a for-profit nationwide healthcare provider founded in 1993, with corporate offices in Irvine, California, and Albuquerque, New Mexico. Sun is a publicly traded corporation subject to Security and Exchange Commission requirements. Sun’s operations included inpatient services, rehabilitation therapy services, and home health; with the majority of its income coming from Medicare and Medicaid programs. In 1999, Sun operated over 300 projects through its Sunbridge subdivision, which had 40 regional offices throughout the nation. Sun obtained the Carmichael facility in 1996 when it acquired the previous owner, Regency Health Services. Regency had ownership interest in the facility since 1988, before HUD insured the mortgage note. Sun renamed the facility the Sunbridge Care and Rehabilitation Center for Carmichael. Sun also operated seven other projects with Federal Housing Administration insured loans, located in California, Maryland, New Hampshire, New Mexico, and Tennessee. As of June 2004, Sun still operated Carmichael and five of these projects. Between 1997 and 2001, the Independent Public Accounting firm of Lesley, Thomas, Schwarz, and Postma, Inc. prepared Carmichael’s annual financial audit reports. These reports were signed by owner representatives and submitted to HUD. HUD did not require a financial audit report for fiscal year 2002. 2 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 FINDING OWNER MISMANAGED THE PROJECT’S OPERATIONS Sun Healthcare did not follow the project’s Regulatory Agreement and other HUD requirements in managing operations of the Carmichael Rehabilitation Center. This included Sun incorporating the project into its petition for bankruptcy and defaulting on the project’s mortgage. In addition, Sun Healthcare inappropriately disbursed $3,769,290 of the project’s cash between January 1997 and September 2002 (see Appendix B). The latter included ineligible distributions to the owner totaling $2,965,619, and use of project funds to pay ineligible ownership costs of $803,671. The inappropriate distributions continued while the project was subject to the owner’s bankruptcy, in default, and HUD held the note. In addition, when the project’s financial audit reports identified a portion of the inappropriate distributions, the owner submitted misleading information to HUD to make it appear the problems had been corrected. This occurred because Sun Healthcare lacked internal controls to ensure it complied with HUD’s requirements. We believe these actions increased the risk to HUD’s mortgage insurance fund by reducing the cash available for the project’s normal operations. In addition, the default directly resulted in HUD incurring a loss of $323,925 on the disposition of the Carmichael facility. HUD Requirements The Regulatory Agreement between HUD and the Carmichael Rehabilitation Center was approved on November 20, 1992. The agreement required the owner to promptly make all payments due under the note, and the owner was also not allowed to include the facility in any petition for bankruptcy. In addition, the owner could not make, receive, or retain any distributions of the project’s assets or income, except surplus cash after the end of annual or semiannual periods. The Agreement stated no distributions could be made when there was a default under the mortgage. All the project’s rents and receipts were supposed to be deposited in the name of the project, and such funds could be withdrawn only for project expenses or allowed surplus cash distributions. Finally, the owner could not have the facility incur any liability or obligation not in connection with the project’s operations. HUD Handbook 4370.2, Revision 1, Financial Operations and Accounting Procedures, dated January 23, 1996, stipulates under Chapter 2 that distributions can only be paid from surplus cash, but cannot be paid when the project is in default. The surplus cash generated at the end of one fiscal period is not available for distribution until the next fiscal period. If the owner takes distributions when the project is in default or when the project is in a non-surplus cash position, the owner is subject to criminal and/or civil penalties. 12 U.S.C. Sec. 1715z-4a states that HUD may recover any assets or income used by any person in violation of a regulatory agreement applicable to a multifamily project insured by HUD. This prohibits owners and their agents from using project resources for anything other than the project’s operating expenses, which are the necessary and reasonable expenses arising from the everyday operation and maintenance of the project. HUD may recover double the value of any assets and income of the project that have been used in violation of the regulatory agreement, plus all related costs such as reasonable attorney and auditing fees. 3 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 HUD Notice 01-3 regarding the Section 232 program, issued April 2001, stipulates any owner or operator of a healthcare facility that has filed for bankruptcy within the last five years, is not eligible to participate in any manner in a facility with a Section 232 insured mortgage. Petition for Bankruptcy and Default Although strictly prohibited by the Regulatory Agreement, Sun incorporated the project into its petition for bankruptcy and defaulted on the project’s mortgage. This activity directly resulted in HUD incurring a loss on the disposition of the Carmichael facility. Sun Healthcare filed for Chapter 11 bankruptcy protection on October 14, 1999, including all its subdivisions, affiliates, and projects (including the Carmichael Rehabilitation Center). Shortly thereafter, Sun began defaulting on the project’s mortgage when it failed to make the December 1999 payment. No subsequent payments were forthcoming, so the lender, the Project Funding Corporation, optioned to assign the note to HUD in May 2000. Since the project was included in Sun’s bankruptcy, it then fell under the jurisdiction of the bankruptcy court. Sun could not bring the mortgage current until its creditors approved its plan of reorganization, which didn’t occur until February 2002. Thus, no mortgage payments were made until March 11, 2002, when Sun Healthcare finally brought the mortgage current with a payment to HUD of $1,129,470. This amount included all delinquent mortgage interest and principal. In July 2002, HUD sold Carmichael’s note at auction without Federal Housing Administration insurance. At that time, the note’s adjusted balance was $4,559,895. However, the adjusted balance received from GE Capital’s winning bid was only $4,235,970. As a result, HUD incurred a loss of $323,925 when the note sale closed in September 2002. Ineligible Distributions to the Owner The Regulatory Agreement strictly limited the distribution amounts the owner could withdraw from the project. However, Sun did not follow these requirements and collected excessive distributions totaling $2,965,619. This resulted from the owner’s practice of transferring and commingling all the project’s cash with its own funds in violation of HUD requirements. Sun Healthcare’s application of an inappropriate cash management system led to excessive distributions of the project’s cash. Project receipts were initially deposited to a project operating bank account, which also held deposits of various other Sun projects. However, Sun then routinely and consistently transferred all the cash to its own bank accounts on the same day as the deposit, which Sun called a “cash sweep.” The sweeps commingled the cash with the owner’s other financial activity, enabling the owner to utilize it for non-project purposes and thus resulting in distributions. According to the Regulatory Agreement, Sun was only allowed to collect a distribution up to the surplus cash amount calculated on the prior year’s financial audit report, and Sun could make no distributions to itself while the project was in default. Nevertheless, the net amounts collected by Sun through these transfers exceeded the available surplus cash between 1997 and 2001. Since Sun did not immediately return the cash to the project, it resulted in ineligible distributions. 4 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 Ineligible Distributions to Owner Fiscal Distribution Surplus Cash Ineligible Year Amount Available (1) Distribution 1997 $ 797,122 $ 543,665 $ 253,457 1998 $ 372,466 $ 288,661 $ 83,805 1999 $ 787,122 $ 271,858 $ 515,264 2000 $ 648,690 None (2) $ 648,690 2001 $ 1,464,403 None (2) $ 1,464,403 Total $ 4,069,803 $ 1,104,184 $ 2,965,619 (1) Based on prior year's financial audit report calculation. (2) No distributions of surplus cash available while project in default. HUD Handbook 4370.1, Reviewing Annual and Monthly Financial Statements, Chapter 2-21, Section J, allows a management agent to deposit project funds in the same bank account as other projects, with HUD’s prior written approval, as long as an agent can identify all receipts and liabilities of individual projects. Although the handbook did amend the Regulatory Agreement to allow a management agent to commingle multiple housing projects in a single account, it did not amend the Regulatory Agreement to allow project funds to be commingled with those of the owner. Since Sun self- managed the facility there was no independent management agent to ensure the proper administration of the funds separate from the owner’s, or prevent its utilization for the owner’s other purposes. In addition, Sun did not obtain HUD approval to commingle funds with other projects or in the owner’s multiple bank accounts, so it was precluded from conducting this activity. Distributions In Excess of Surplus Cash Identified on Financial Audit Reports Although the project’s financial audit reports did not identify all the inappropriate distributions (above), they did identify approximately $1.5 million of distributions in excess of surplus cash, including $458,097 on the 2000 report and $1,056,740 on the 2001 report. The audit reports recommended that Sun Healthcare return the funds to the project’s operating account, and for Sun to amend its procedures to assure distributions do not exceed the allowable surplus cash. Sun Healthcare’s Vice-President and Corporate Controller attested that these funds had been returned to the project’s operating account in the project’s 2001 financial statements submitted to HUD. However, we found that Sun did not fully comply with these recommendations. Although Sun claimed the funds were returned to the operating account, this was not completely accurate. To resolve the 2000 recommendation, Sun made a deposit of $458,097 to the project’s operating account on March 7, 2002. However, the funds were immediately swept back to Sun’s own bank accounts on the same day. As a result, the problem was not appropriately corrected. We also noted that no cash was returned to the project’s operating account to resolve the 2001 recommendation. In addition, the cash management practices were never amended to prevent this activity, at least up through September 2002. 5 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 Ineligible Ownership Expenses Sun Healthcare inappropriately charged the project $803,671 for expenses associated with its ownership of the facility without obtaining HUD’s permission. This included income tax liabilities charged prior to and during the default, and goodwill expenses charged to the facility prior to the mortgage default. These were Sun’s ownership expenses, as defined by HUD handbooks, and should not have been charged to the project without HUD’s prior approval. HUD Handbook Criteria HUD Handbook 4370.2, Financial Operations and Accounting Procedures for Insured Multifamily Projects, Chapter 4-4, Section G, distinguishes mortgagor/corporate expenses from expenses necessary and reasonable for the operation of the project. Mortgagor/corporate expenses include federal and state income taxes. The handbook states owners may only charge these expenses against the project’s operations with the prior written approval of HUD. Handbook 4370.4, Basic Accounting Desk Reference for HUD Loan Servicers, Chapter 4-3, states corporate expenses may represent diversions of project funds for unauthorized purposes. The handbook also lists federal and state taxes as corporate expenses. Inappropriate Application of Income Taxes Between 1997 and 2001, Sun permanently reduced the cash amounts it owed the project by charging income taxes totaling $686,541 (see Appendix B). According to HUD requirements, income taxes are an expense of the owner, which should not have been charged to the project without HUD’s prior written approval. Sun never obtained HUD’s permission to charge these costs to the project. However, this liability was still applied to Carmichael through annual adjustments treating the ownership expense as a project liability, which affected the asset balances included on the financial audit reports submitted to HUD. Although the income taxes were shown on the project’s income statements, included as part of the financial audit reports, Sun did not provide any information to HUD concerning the inappropriate adjustments. Ineligible Goodwill Expense The owner charged ineligible expenses to the project totaling $117,130 (see Appendix B), which Sun identified as goodwill1 expense. The owner initially charged the goodwill expense to the project in 1998 through a series of monthly inter-company accounting entries totaling $150,108. The owner later reduced this amount by $108,032, leaving a net goodwill expense amount of $42,076. In 1999, Sun charged another $75,054 to the project. These goodwill expenses are corporate expenses of Sun Healthcare, and are not reasonable and necessary for the operation of the project. These expenses reduced the cash balance Sun owed to the project. As a result, the expense was, in effect, an additional inappropriate distribution to the owner in violation of the Regulatory Agreement. 1 Goodwill represents the amount an organization paid to acquire another entity over its estimated fair value. Sun Healthcare recorded goodwill in its corporate books when it acquired Regency, the prior owner of the Carmichael facility. 6 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 AUDITEE COMMENTS AND OIG EVALUATION We provided our draft report to the auditee for its comments on September 2, 2004. We also discussed the draft report during an exit conference discussion with Sun Healthcare officials on September 3, 2004. The auditee provided its comments on September 20, 2004. Sun Healthcare issued its comments through the Carmichael Rehabilitation Center. We included the auditee’s final written comments in Appendix C to the report, including all attachments. In general, the auditee did not agree with our conclusions over the bankruptcy and default, excessive distributions, and ineligible expenses. All comments were considered but no material changes were made to our report. Bankruptcy and Mortgage Default Comments Synopsis: The auditee stated that bankruptcy codes barred the application and effects of the Regulatory Agreement and subsequent administrative action. The auditee also blamed the loss on HUD’s decision to sell the note. Sun believed HUD could have waited and sold the note at some subsequent date when it would not have incurred a loss. OIG Evaluation: We do not agree with the auditee’s position that HUD was the cause for the loss on the sale of the mortgage. Sun Healthcare included the project in a bankruptcy petition and stopped making mortgage payments in violation of the Regulatory Agreement, resulting in the note being assigned to HUD. There was also no evidence to show that putting off the note sale until some unidentified future date would have further reduced HUD’s losses. In addition, the bankruptcy codes cited by the auditee do not clearly bar HUD from pursuing appropriate action against the auditee. Cash Management Comments Synopsis: The auditee did not believe it was in violation of HUD requirements, insisting that the provisions of Handbook 4370.2 were met. The auditee argued this handbook did not require a management agent to be independent, nor require prior approval from HUD to utilize a centralized account. As a result, cash sweeps should not be considered distributions. 7 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 OIG Evaluation: Although HUD Handbook 4370.2 does not specifically mention whether HUD approval is required, Handbook 4370.1, Chapter 2, states the commingling of funds between projects is only permissible with the advance approval of HUD. In addition, both handbooks required the cash to be maintained in a single centralized bank account, allowing only a single separate subsidiary payroll bank account. Sun Healthcare’s practice of sweeping cash did not follow HUD’s conditions for the utilization of a centralized account. Sun did not maintain the project’s cash balance in one centralized bank account, but instead swept it from the project bank account to its own accounts. Sun then further transferred these funds to various other corporate bank accounts and its revolving line of credit, commingling the cash with various other corporate funds. This made the project’s separate cash balance in these bank accounts unidentifiable, and provided Sun the means to utilize it for non- project purposes. If a management agent maintained the project’s cash in a single joint account in accordance with HUD requirements, it would not have been available for the owner’s benefit. As a result, the cash sweeps resulted in distributions to the owner. Financial Audit Findings on Excessive Distributions Comments Synopsis: The auditee stated the project had access to the cash at all times prior to fiscal year 2000, so there were no distributions. Sun claimed it treated the 2000 and 2001 activity as excessive distributions because the bankruptcy limited the availability of the funds held by Sun to the project. The auditee did not believe the statute (12 U.S.C. Sec. 1715z-4a) was applicable because all excessive distributions were repaid in 2002, leaving no remaining ineligible amounts. Sun maintained the temporary March 2002 deposit of $458,097 resolved the 2000 financial audit finding by making the cash available to the project. Sun therefore recomputed the 2000 negative surplus cash balance to include the deposit, which also reduced the excessive distributions it reported to HUD for 2001. In addition, Sun believed the payment of $1,129,470 on March 11, 2002 to bring the mortgage current sufficiently resolved all remaining distributions. OIG Evaluation: The auditee’s positions over distributions and the availability of funds were not plausible. If Sun believed the cash was restricted in 2000 and 2001 then it should have identified all prior years excessive transfers as excessive distributions, since they were still held by Sun, and returned these funds to the project. In addition, there was no information to show that the bankruptcy court precluded Sun from resolving the distribution problem. Sun could have left receipts in the project’s operating account, immediately transferred previously swept cash back to that account, or even held the project funds in an escrow account in the name of the project. The 2002 deposit of $458,097 to the project’s operating account did not resolve the 2000 financial audit finding, since it was immediately swept back to the owner’s accounts. In addition, Sun should 8 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 not have retroactively applied this deposit to the negative surplus cash reported on the 2000 financial audit, just so it could understate the 2001 finding amount. The owner did bring the mortgage current in March 2002 to prevent a HUD foreclosure. However, this payment did not change the fact that Sun had already violated the regulatory agreement in 2001 by distributing funds in excess of surplus cash. In addition, the payment did not address the total balance of excessive distributions (see Appendix B). 1999 Surplus Cash Comments Synopsis: The auditee stated it should have been allowed to collect the project’s 1999 surplus cash in calendar year 2000, despite the mortgage default. The auditee asserted HUD was obligated to apply the project’s Reserve for Replacement funds to temporarily cover the mortgage payments, making the surplus cash available to Sun. OIG Evaluation: We do not agree with the auditee’s assertions over the application of the project’s Reserve for Replacements funds. The purpose of the reserve was for the replacement of the project’s capital items. HUD was not required to allow these funds to cover the owner’s nonpayment of the mortgage, which would have only temporarily delayed the default and subsequent assignment. It would not have been reasonable for HUD to allow an owner to deplete the project’s reserves, just so the owner could collect surplus cash. Ineligible Ownership Income Taxes Comments Synopsis: The auditee stated that even though it did not obtain prior HUD approval, it should still be allowed to charge the project for the income taxes. The auditee referred to HUD handbook requirements, which state that HUD may approve such expenses. Sun also stated the income taxes were Carmichael Rehabilitation Center, Inc.’s responsibility, not Sun Healthcare’s. OIG Evaluation: The auditee never obtained HUD’s prior written permission to charge the income taxes to the project. As a result, the auditee was in violation of HUD handbook requirements. Just because HUD had the option of granting such permission, does not mean the auditee was automatically entitled to charge the project. 9 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 Ineligible Ownership Goodwill Comments Synopsis: Sun acknowledged goodwill amortization was a corporate expense, but claimed the charges to the project were in accordance with standard company and industry practices and generally accepted accounting principles. The auditee also wanted credit for management fees it could have charged the project. OIG Evaluation: Whether or not Sun’s internal policies called for these expenses to be allocated to the facility level does not change the fact that they were ineligible ownership expenses in violation of the Regulatory Agreement and other HUD requirements. The goodwill was not a project asset so the associated amortization expense was not a reasonable and necessary project expense. Sun’s request to now retroactively charge a management fee to offset ineligible expenses is not reasonable. RECOMMENDATIONS We recommend the Director of Multifamily Housing: 1A. Pursue recovery from Sun Healthcare of the $323,925 loss incurred on the sale of the mortgage note. 1B. Take appropriate administrative action and pursue recovery of the net ineligible distributions amount of $3,769,290 from Sun Healthcare, as permitted by statute (12 U.S.C. Sec. 1715z- 4a). 10 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 MANAGEMENT CONTROLS In planning and performing our audit, we considered the management controls relevant to the Carmichael Rehabilitation Center and Sun Healthcare activity to determine our audit 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 that the following management controls were relevant to our audit objectives: • Controls and procedures over cash management of project funds • Controls and procedures over project disbursements and expenses It is a significant weakness if management controls do not provide reasonable assurance that the process for planning, organizing, directing, and controlling program operations will meet an organization’s objectives. Based on our review, we believe there was a significant weakness in Sun Healthcare’s lack of policies and procedures to ensure it followed HUD Handbook and Regulatory Agreement requirements over cash management and disbursement of project funds. 11 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 Appendix A SCHEDULE OF QUESTIONED COSTS Finding Number Type of Questioned Cost Funds to be Put to Ineligible 1/ Unsupported 2/ Better Use 3/ 1A $323,925 1B $3,769,290 1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity that the auditors believed 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 the 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. 3/ Funds to be put to better use are costs that will not be expended in the future if our recommendations are not implemented; for example, 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. 12 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 Appendix B Ineligible Diversions of Carmichael's Funds Inappropriate Activity 1997 1998 1999 2000 2001 Total Ineligible Distributions $253,457 $ 83,805 $515,264 $648,690 (1) $ 1,464,403 (2) $ 2,965,619 Ownership Goodwill Expense $ 42,076 $ 75,054 $ 117,130 Ownership Income Taxes $231,000 $128,510 $251,031 $ 29,300 $ 46,700 $ 686,541 Total Ineligible Diversions $484,457 $254,391 $841,349 $ 677,990 $ 1,511,103 $ 3,769,290 Period project in default on mortgage, December 1999 through March 2002. (1) - Financial audit report for fiscal year 2000 only identified $458,097 of the ineligible distributions. (2) - Financial audit report for fiscal year 2001 only identified $1,056,740 of the ineligible distributions. 13 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 Appendix C AUDITEE COMMENTS 14 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 15 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 16 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 17 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 18 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 19 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 20 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 21 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 22 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 23 Telephone: (213) 894-8016 http://www.hud.gov/offices/oig/ Fax: (213) 894-8115 24
The Carmichael Rehabilitation Center Federal Housing Administration Project Number 136-43061 Carmichael, California
Published by the Department of Housing and Urban Development, Office of Inspector General on 2004-11-04.
Below is a raw (and likely hideous) rendition of the original report. (PDF)