AUDIT REPORT Lower Manhattan Development Corporation Community Development Block Grant Disaster Assistance Fund New York, New York 2005-NY-1008 September 27, 2005 OFFICE OF AUDIT New York/New Jersey Region Issue Date September 27, 2005 Audit Report Number 2005-NY-1008 TO: Nelson R. Bregon, General Deputy Assistant Secretary for Community Planning and Development, D FROM: Edgar Moore, Regional Inspector General for Audit, 2AGA SUBJECT: Lower Manhattan Development Corporation, New York, New York, Community Development Block Grant Disaster Assistance Funds HIGHLIGHTS What We Audited and Why Pursuant to a congressional mandate, we performed the fifth of our ongoing audits of the Lower Manhattan Development Corporation’s (the auditee) administration of the Community Development Block Grant (Block Grant) Disaster Assistance funds provided to the State of New York following the September 11, 2001, terrorist attacks on the World Trade Center in New York City. The U.S. Department of Housing and Urban Development (HUD) has allocated $2.783 billion in Disaster Assistance funds to the auditee, and during our audit period of October 1, 2004, through March 31, 2005, the auditee disbursed $47 million of these funds for activities related to the rebuilding of lower Manhattan. Our audit objectives were to determine whether the auditee (1) disbursed Disaster Assistance funds in accordance with HUD-approved action plans, (2) expended Disaster Assistance funds for eligible planning and administrative expenses in accordance with applicable laws and regulations, (3) maintained a financial management system that adequately safeguarded Disaster Assistance funds, and (4) developed and implemented procedures to recover funds owed to the Residential Grant Program. What We Found We found that the auditee generally disbursed Disaster Assistance funds in accordance with the HUD-approved action plans. The auditee also expended Disaster Assistance funds for eligible planning and administrative expenses in accordance with applicable laws and regulations, and maintained a financial management system that adequately safeguarded the funds. However, the auditee disbursed $2,028,282 in Disaster Assistance funds for items either not included in the budget of the subrecipient agreement for the Hudson River Park Improvements Program, or for costs incurred before the time of performance specified in the agreement. Additionally, the auditee developed and implemented collection procedures to recover funds owed to the Residential Grant Program. However, its collection efforts were not always fully documented, and there is a need to consider additional actions to recover amounts owed. What We Recommend We recommend that HUD’s general deputy assistant secretary for community planning and development require the auditee to reimburse the $2,028,282 disbursed for expenses either not included in the budget of the subrecipeint agreement for the Hudson River Park Improvements Program, or for costs incurred before the time of performance specified in the agreement. This reimbursement should be from nonfederal funds so that the funds can be put to better use. We also recommend that the auditee maintain complete documentation of its efforts to collect amounts owed to the Residential Grant Program and consider additional actions to address the collection of the $6.4 million owed to the Residential Grant Program as of March 31, 2005. For each recommendation without a management decision, please respond and provide status reports in accordance with HUD Handbook 2000.06, REV-3. Please furnish us copies of any correspondence or directives issued because of the audit. Auditee’s Response Auditee officials generally agreed with our findings, and noted that action has been taken to address the issues raised. Specifically, the auditee advised that it obtained additional invoices for costs that conform to the subrecipient agreement under the Hudson River Park Improvement Program to substitute for the costs found not to conform to the agreement. The auditee is also considering additional procedures to collect funds owed to the Residential Grant Program. We discussed the contents of the report with the auditee during the audit and at an exit conference on September 14, 2005, and they provided written comments on September 21, 2005. The complete text of the auditee’s comments can be found in Appendix B. 2 TABLE OF CONTENTS Background and Objectives 4 Results of Audit Finding 1 Disaster Assistance Funds Were Disbursed Contrary to the Terms of the Subrecipient Agreement for the Hudson River Park Improvements Program 6 Finding 2 Residential Grant Program Collection Efforts Need to be Fully Documented and Additional Actions Should Be Considered 8 Scope and Methodology 11 Internal Controls 12 Followup on Prior Audits 14 Appendixes A. Schedule of Questioned Costs and Funds to Be Put to Better Use 15 B. Auditee Comments and OIG’s Evaluation 16 C. Schedule of Program Funding and Disbursements as of March 31, 2005 20 3 BACKGROUND AND OBJECTIVES The September 11, 2001, terrorist attacks on the World Trade Center in lower Manhattan took a devastating toll on New York City. Negative impacts were immediately felt in both the housing market and the quality-of-life in lower Manhattan. The development of programs with significant incentives, encouraging individuals to remain in or move to housing in lower Manhattan, as well as improving the living conditions in lower Manhattan, was greatly needed. In the aftermath of the terrorist attacks, Congress authorized the U.S. Department of Housing and Urban Development (HUD) to provide the State of New York with $3.483 billion in Community Development Block Grant (Block Grant) Disaster Assistance. On November 5, 2001, the Office of Management and Budget designated $700 million in Block Grant funding for New York City out of the Emergency Response Fund that Congress had appropriated. 1 On January 10, 2002, Congress appropriated an additional $2 billion for Block Grant funding, earmarking at least $500 million to compensate small businesses, nonprofit organizations, and individuals for their economic losses. 2 On August 2, 2002, Congress appropriated an additional $783 million in Block Grant funding. 3 The Lower Manhattan Development Corporation (auditee) was created in December 2001 as a subsidiary of the Empire State Development Corporation to function as a joint city-state development corporation. The auditee was designated by the State of New York to develop programs and distribute $2.783 billion of the $3.483 billion appropriated by Congress in the January and August 2002 Emergency Supplemental Acts. The Empire State Development Corporation, the parent company of the auditee, administers the remaining $700 million. A 16-member board of directors, appointed equally by the governor of New York and the mayor of New York City, manages the affairs of the auditee. The Auditee’s chairman of the board is Mr. John C. Whitehead, and its president is Mr. Stefan Pryor. The Empire State Development Corporation performs all accounting functions for the auditee, including payroll, payments to the auditee’s vendors, and drawing down funds from HUD. As of March 31, 2005, HUD had approved 10 partial action plans for the auditee, which allocated approximately $1.9 billion, or 68.7 percent, of the $2.783 billion appropriated (See appendix C for programs and amounts). As of March 31, 2005, the auditee had disbursed $877 million, or 46 percent, of the $1.9 billion allocated. 1 2001 Emergency Supplemental Appropriations Act for Recovery from and Response to Terrorist Attacks on the United States, Pub. L. 107-38, 115 Stat. 220 (2001). 2 The Department of Defense and Emergency Supplemental Appropriations for Recovery from and Response to Terrorist Attacks on the United States Act 2002 (Emergency Supplemental Act 2002), Pub. L. 107-117, 115 Stat. 2336 (2002). 3 The 2002 Supplemental Appropriations Act for Recovery from and Response to Terrorist Attacks on the United States, Pub. L. 107-206. 4 For the audit period of October 1, 2004, through March 31, 2005, we reviewed disbursements related to the following: (1) the World Trade Center Memorial and Cultural Program; (2) the Hudson River Park Improvements Program; (3) the Lower Manhattan Tourism Program, and (4) the auditee’s planning and administrative expenses. In addition, we reviewed the auditee’s efforts to collect amounts owed to the Residential Grant Program, as well as funds disbursed for planning and administrative expenses related to the Utility Restoration and Infrastructure Rebuilding Program. For the items tested, our review disclosed expenditure exceptions under the Hudson River Park Improvements Program and in the auditee’s documentation of collection efforts taken to recover funds owed to the Residential Grant Program. Hudson River Park Improvements Program Under Partial Action Plan No. 4, approved by HUD on August 6, 2003, the auditee proposed to provide up to $2.6 million for improvements to Hudson River Park. The improvements include creating a set of new tennis courts and converting the courtyard of the Pier 40 complex at Houston Street into recreational field space for use as baseball and soccer fields. The auditee believes that the creation of these public recreational facilities will improve the quality of life in lower Manhattan, making it a more desirable place to live, which will not only help retain existing residents, but also attract more residents and visitors to the area. The auditee executed a subrecipient agreement appointing the Hudson River Park Trust as the administrator of the program. Funds for this program come from the initial $2 billion appropriation Congress authorized on January 10, 2002, under the Defense Appropriations Act of 2002, Public Law 107- 117. Residential Grant Program On June 7, 2002, HUD approved Partial Action Plan No. 1, which allocated $280,500,000 to the Residential Grant Program. This program seeks to compensate individuals for the extraordinary expenses they may have incurred as a result of the disaster, as well as create incentives for individuals and families to rent, purchase, or remain in housing in lower Manhattan. We audited the Residential Grant Program in two of our prior audits. The auditee established a master repayment list to monitor funds owed the Residential Grant Program due to processing errors and/or recipients that broke the grant commitment to reside at an eligible address for two years. Our audit objectives were to determine whether the auditee (1) disbursed Disaster Assistance funds in accordance with HUD-approved action plans, (2) expended Disaster Assistance funds for eligible planning and administrative expenses in accordance with applicable laws and regulations, (3) maintained a financial management system that adequately safeguarded Disaster Assistance funds, and (4) developed and implemented procedures to recover funds owed to the Residential Grant Program. 5 RESULTS OF AUDIT Finding 1: Disaster Assistance Funds Were Disbursed Contrary to the Terms of the Subrecipient Agreement for the Hudson River Park Improvements Program Our review disclosed that the auditee disbursed Disaster Assistance funds for costs that did not conform to the subrecipient agreement for the Hudson River Park Improvements Program. It allowed Disaster Assistance funds to be disbursed for (a) items not included in the budget of the subrecipient agreement and (b) costs incurred before the time of performance date specified in the subrecipient agreement. These deficiencies occurred because the auditee did not ensure that the invoices submitted for payment complied with the subrecipient agreement. As a result, $2,028,282 was disbursed for items either not included in the budget of the subrecipeint agreement for the Hudson River Park Improvements Program, or for costs incurred before the time of performance specified in the subrecipient agreement. Consequently, the auditee should be required to reimburse the $2,028,282 disbursed so that these funds can be put to better use. Funds Disbursed for Costs Not Approved in the Subrecipient Agreement The auditee disbursed $734,651 for costs that were not initially approved as budgeted items under the subrecipient agreement related to the Hudson River Park Improvements Program. Section III of the subrecipient agreement, entitled “Budget,” provides that the auditee is to fund $2.6 million of the $6,652,506 overall program budget. The agreement allocated the $2.6 million between two activities: tennis courts (budget line item C 4082), funded at $1,002,229 and Pier 40 general construction (budget line item C 4108), funded at $1,597,771. Section X, item D.2, of the subrecipient agreement, entitled “Subcontracts,” provides that the “Subrecipient shall not enter into any subcontracts with any agency or individual in the performance of this agreement without the written consent of Grantee [the auditee] prior to the execution of such subcontract agreement.” The subrecipient submitted and the auditee reimbursed four invoices totaling $670,078 for work done by an electrical subcontractor under budget line item C 4110, which was not approved to be funded by the auditee under the subrecipient agreement. These invoices were dated between July and November 2004 and were paid in January 2005. We found no evidence that the auditee gave written consent to the subrecipient for the services of the electrical subcontractor. We also found that the auditee reimbursed the subrecipient $64,573 for granite materials purchased directly by the subrecipient from a supplier and invoiced to the auditee as a reimbursement to the general contractor. However, granite materials were not identified in the subrecipient agreement as being funded by the auditee. 6 Funds Disbursed for Services Performed Before the Time of Performance Specified in the Subrecipient Agreement Section II of the subrecipient agreement, entitled “Time of Performance,” provides that services of the subrecipient are to start on August 1, 2004. Section IV, entitled “Payment,” provides that payment of eligible expenses shall be made against the line item budgets specified in section III (“Budget”) and in accordance with performance as specified in sections I and II (“Scope of Service” and “Time of Performance”). However, during our review of the supporting documentation for the invoices submitted by the subrecipient, we found four invoices totaling $1,293,631 for services performed before August 1, 2004, which were reimbursed by the auditee. Although these services were for tennis courts ($440,721) and Pier 40 general construction ($852,910), the costs were incurred before the time of performance specified in the subrecipient agreement; therefore, they should not be allowed. Recommendations We recommend that HUD’s general deputy assistant secretary for community planning and development require the auditee to 1A. Reimburse from nonfederal sources the $2,028,282 disbursed under the Hudson River Park Improvements Program so that these funds can be put to better use. 1B. Review and enhance its control procedures to ensure that Disaster Assistance funds are disbursed for only contracted items and costs incurred during the time of performance specified in the subrecipient agreement. 7 Finding 2: Residential Grant Program Collection Efforts Need to be Fully Documented and Additional Actions Should Be Considered The auditee developed and implemented procedures to recover funds owed to the Residential Grant Program; however, its collection efforts were not always fully documented, and there is a need to consider additional actions to recover amounts owed. To date, the auditee concentrated on disbursing program funds to encourage individuals to maintain housing in lower Manhattan rather than on collection activities. Consequently, the auditee needs to fully document its collections efforts and consider additional actions to address recovery of the $6,441,103 owed by Residential Grant Program recipients as of March 31, 2005, so that these funds can be put to better use. Auditee Collection Procedures As of March 31, 2005, Residential Grant Program recipients owed $6,441,103 to the program. While some of the $6.4 million was due to erroneous payments, $6.1 million, or 95 percent, was the result of program recipients who broke the commitment made under the program regulations to reside in lower Manhattan for at least two years. The auditee tracks amounts owed to the Residential Grant Program through its master repayment list and has established procedures to recover funds owed. The program administrator for the Residential Grant Program sends a letter to recipients who have broken their commitment to reside at an eligible address for two years in accordance with the guidelines. The auditee sends an initial letter to recipients requesting repayment of funds owed 30 days after the program administrator’s letter. If no response is received, the auditee sends another letter 60 days after the initial request for repayment. For those Residential Grant Program recipients who have been identified as owing funds due to errors, the auditee sends a letter requesting repayment, and if no response is received, the auditee sends another letter 60 days after the initial request for repayment. To date, additional collection procedures have not been established. Documentation of Collection Efforts Was Incomplete Our review and testing of grant recipients listed on the master repayment list as of March 31, 2005, found that the auditee properly accounted for funds repaid to the Residential Grant Program. We also found that the auditee maintained several files that track the date and type of letter sent, as well as the postal service certified letter number, if applicable. However, the auditee did not have complete documentation of the actions taken to collect all amounts owed to the 8 Residential Grant Program. Our review of 110 Residential Grant Program recipients to whom the auditee sent 30 or 60 day letters disclosed that the auditee did not document that letters were sent to 25 recipients. Auditee officials advised that letters were sent to the 25 recipients by its consultant that maintained the master repayment list. Nevertheless, to document a complete audit trail, all correspondence related to the auditee’s collection actions, should be maintained to facilitate review and audit by HUD as required by the alternative procedures published in the Federal Register. Additional Collection Action Needs to Be Considered The auditee’s collection procedures consist of sending 30 and 60 day letters, permitting an appeal process, and allowing amounts owed to be written off if certain conditions have been met. Through March 31, 2005, the auditee had granted appeals, reversed denials, collected, and/or written off $3,093,947 of amounts originally owed to the Residential Grant Program. Auditee records report that $6.4 million is currently owed the Residential Grant Program. However, to ensure collection of these funds, additional analysis of the balance should be initiated to determine the collection potential of the accounts and what if any alternative collection activity is needed. Our analysis of these accounts is presented in the chart below. Of the total 1,225 accounts, 72 accounts owing $1,000 or less comprised less than half a percent of all amounts owed. In addition, 606 recipients, owing more than $5,000 but less than $12,000, accounted for 73 percent of all funds owed. Therefore, the auditee should analyze these accounts for collectibility and consider additional action to address the recovery of the $6,441,103 owed, so that any recovered funds can be put to better use. 9 Residential Grant Program recipients with balances owed 100% $7,000,000 $6,441,103 $6,000,000 73.35% $5,000,000 $4,724,795 Amount of funds owed $4,000,000 Count 1,225 $3,000,000 26.21% $2,000,000 $1,688,250 606 $1,000,000 .44% 547 72 $28,058 $0 < 1,000.00 1,000.00 -> 4,999.99 5,000.00 -> 12,000.00 Range of balances Auditee officials stated that their efforts were concentrated on disbursing Residential Grant Program funds to individuals to encourage them to maintain housing in lower Manhattan. Further, the auditee stated that it is exploring the possibility of contracting with a collection agency or having in-house legal personnel pursue outstanding Residential Grant Program amounts owed. The auditee should consider these viable options. Recommendations We recommend that HUD’s general deputy assistant secretary for community planning and development require the auditee to 2A. Ensure that its efforts to collect amounts owed to the Residential Grant Program are fully documented. 2B. Consider additional actions to address the collection of the $6,441,103 owed to the Residential Grant Program so that these funds can be put to better use. 10 SCOPE AND METHODOLOGY The auditee received $2.783 billion in Disaster Assistance Funds from HUD. During our audit period, October 1, 2004, through March 31, 2005, the auditee disbursed $47 million of these funds for activities related to the rebuilding of lower Manhattan. We tested $24 million, representing approximately 51 percent of the amount disbursed for the period. To achieve our audit objectives we reviewed • Applicable laws, regulations, and program requirements; • HUD-approved partial action plans; and • The auditee’s accounting books and records. We examined and tested the documentation supporting disbursements related to the following programs: - World Trade Center Memorial and Cultural - Hudson River Park Improvements - Lower Manhattan Tourism In addition, we reviewed the payroll records and timesheets of the auditee’s subrecipient for the Utility Restoration and Infrastructure Rebuilding Program. We also reviewed the Auditee’s procedures for recovering funds owed to Residential Grant Program. In review of the Hudson River Park Improvements Program, we tested 100 percent of the disbursements made for the period because the population was relatively small and it was feasible for us to review each item in the population. We used representative (nonstatistical) sampling to assess the auditee’s procedures for recovering funds owed to the Residential Grant Program. The audit covered the period from October 1, 2004, through March 31, 2005, and was expanded when necessary. We performed our on-site work at the auditee’s office, the office of program administrator for the Residential Grant Program, and the office of the auditee’s parent company, the Empire State Development Corporation, from April through August 2005. We performed our review in accordance with generally accepted government auditing standards. 11 INTERNAL CONTROLS Internal controls are an integral component of an organization’s management that provides reasonable assurance that the following objectives are achieved: • Effectiveness and efficiency of operations, • Reliability of financial reporting, and • Compliance with applicable laws and regulations. Internal controls relate to management’s plans, methods, and procedures used to meet its mission, goals, and objectives. Internal controls include the processes and procedures for planning, organizing, directing, and controlling program operations. They include the systems for measuring, reporting, and monitoring program performance. Relevant Internal Controls We determined the following internal 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. • 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. • 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. We assessed the relevant controls identified above. A weakness exists if management controls do not provide reasonable assurance that the process for planning, organizing, directing, and controlling program operations will meet the organization’s objectives. 12 Weaknesses Based on our review, we believe that the following controls contain reportable weaknesses: • Program operations –The Auditee’s collection efforts were not always fully documented and additional actions to recover funds owed to the Residential Grant Program need to be considered (see finding 2). • Compliance with laws and regulations – Funds were disbursed for either items not included in the budget of the subrecipient agreement for the Hudson River Park Improvements Program, or for costs incurred before the time of performance specified in the subrecipient agreement (see finding 1). 13 FOLLOWUP ON PRIOR AUDITS Prior Report Number and Date We issued Audit Report number 2005-NY-1003 on March 23, 2005. The report contained two audit findings with recommendations for corrective action. The findings involved deficiencies in the administrative costs related to the Utility Restoration and Infrastructure Rebuilding Program and lack of written documentation to ensure monitoring was performed. The auditee has implemented corrective actions to address our cited deficiencies, and the HUD Office of Community Planning and Development established September 30, 2005, as the target date for the Auditee to complete its corrective actions and for HUD to verify the corrective actions were taken. We issued Audit Report number 2004-NY-1004 on September 15, 2004. The report contained one audit finding with recommendations for corrective action. The finding involved deficiencies in the processing of businesses applications for grants under the Employment Training Assistance Program. The auditee has implemented corrective actions to address our cited deficiencies, and the HUD Office of Community Planning and Development has extended the established target date to September 30, 2005, to verify the corrective actions. 14 APPENDIXES Appendix A SCHEDULE OF QUESTIONED COSTS AND FUNDS TO BE PUT TO BETTER USE Recommendation Funds to be put number to better use 1/ 1A $ 2,028,282 2A $ 6,441,103 Total $ 8,469,385 1/ “Funds to be put to better use” are quantifiable savings that are anticipated to occur if an Office of Inspector General (OIG) recommendation is implemented, resulting in reduced expenditures at a later time for the activities in question. This includes costs not incurred, deobligation of funds, withdrawal of interest, reductions in outlays, avoidance of unnecessary expenditures, loans and guarantees not made, and other savings. 15 Appendix B AUDITEE COMMENTS AND OIG’S EVALUATION Ref to OIG Evaluation Auditee Comments 16 Appendix B AUDITEE COMMENTS AND OIG’S EVALUATION Ref to OIG Evaluation Auditee Comments Comment 1 Comment 2 17 Appendix B AUDITEE COMMENTS AND OIG’S EVALUATION Ref to OIG Evaluation Auditee Comments Comment 3 Comment 4 18 Appendix B AUDITEE COMMENTS AND OIG’S EVALUATION Comment 1 The auditee concurs with the finding. It has obtained additional invoices from the subrecipient for costs that conform to the subrecipient agreement under the Hudson River Park Improvement Program to substitute for the $2,028,282 in costs that did not conform. We recommend that HUD verify the eligibility of the substituted costs and ensure that the implemented procedures are operating as intended. Comment 2 The auditee concurs with the recommendation and plans to conduct training that will emphasize ensuring that Disaster Assistance funds are disbursed only for eligible expenses within the scope of applicable agreements. Comment 3 The auditee concurs with the finding. Comment 4 The auditee has agreed to consider additional collection procedures, and will continue to implement the current collection procedures. 19 Appendix C SCHEDULE OF PROGRAM FUNDING AND DISBURSEMENTS AS OF MARCH 31, 2005 Audit period disbursements Cumulative Balance Budget as of October 1, 2004 – disbursed as of remaining as of PROGRAM March 31, 2005 March 31, 2005 March 31, 2005 March 31, 2005 Residential Grant $280,500,000 $11,828,197 $231,696,699 $48,803,301 Employment Training 500,000 38,643 265,452 234,548 Assistance Memorial Design and 350,000 0 299,969 50,031 Installation Columbus Park Renovation 428,571 0 0 428,571 Marketing History/ 4,664,000 857,383 1,316,778 3,347,222 Heritage Museums Downtown Alliance 4,000,000 1,364,129 4,000,000 0 Streetscape New York Stock Exchange 10,160,000 0 0 10,160,000 Area Improvements Parks and Open Space 27,481,689 0 0 27,481,689 Hudson River Park 2,600,000 2,466,968 2,466,968 133,032 Improvements Millennium High School 3,007,500 0 0 3,007,500 West Street Pedestrian 21,155,811 1,591,172 12,840,920 8,314,891 Crossing Public Service Activities 7,296,900 1,512,258 1,771,044 5,525,856 Lower Manhattan Community Outreach 1,000,000 330,060 540,760 459,240 Green Roof Project 100,000 0 0 100,000 Chinatown Tourism and Marketing 1,000,000 111,000 333,500 666,500 Lower Manhattan Information 2,570,000 921,072 921,072 1,648,928 4 Business Recovery Grant 224,500,000 -100,112 13,909,338 10,590,662 Job Creation and Retention 150,000,000 3,133,000 53,710,020 96,289,980 Small Firm Attraction 50,000,000 0 0 50,000,000 Grant World Trade Center 265,077,400 13,161,057 111,378,213 153,699,187 Memorial and Cultural Lower Manhattan Tourism 3,450,000 1,642,835 1,880,447 1,569,553 Disproportionate Loss of 33,000,000 0 32,999,997 3 Workforce Utility Restoration and 735,000,000 0 160,313,178 574,686,822 Infrastructure Rebuilding Administration and 85,459,938 8,098,062 46,758,704 38,701,234 Planning TOTALS 1,913,301,809 $46,955,725 $877,403,059 $1,035,898,750 4 Represents funds collected and returned to the program. 20
Lower Manhattan Development Corporation's Administration of Community Development Block Grant, Disaster Assistance Funds, New York, New York
Published by the Department of Housing and Urban Development, Office of Inspector General on 2005-09-27.
Below is a raw (and likely hideous) rendition of the original report. (PDF)