oversight

The Orlando Housing Authority Did Not Ensure That All Section 8 Units Met Housing Quality Standards and Paid Excessive Subsidies for Some Units

Published by the Department of Housing and Urban Development, Office of Inspector General on 2006-05-31.

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

                                                                    Issue Date
                                                                             May 31, 2006
                                                                    Audit Report Number
                                                                                 2006-AT-1010




   TO:         John G. Niesz, Director, Office of Public Housing, 4HPH


   FROM:
               James D. McKay
               Regional Inspector General for Audit, 4AGA

   SUBJECT:    The Orlando Housing Authority Did Not Ensure That All Section 8 Units Met
               Housing Quality Standards and Paid Excessive Subsidies for Some Units


                                      HIGHLIGHTS

    What We Audited and Why


               We audited the Orlando Housing Authority’s (Authority) Section 8 Housing
               Choice Voucher program as part of the Department of Housing and Urban
               Development (HUD), Office of the Inspector General’s (OIG) annual audit plan.
               We selected the Authority for review based on a Section 8 risk assessment we
               conducted. The audit objectives were to determine whether the Authority made
               Section 8 subsidy payments only for units that met housing quality standards and
               whether subsidy payments were limited to the amount allowed for the unit size
               authorized by each family’s composition.


    What We Found


               Of the 67 units inspected, 20 did not meet standards of which 8 units were in
               material noncompliance. This condition occurred because the Authority’s
               inspectors did not identify the unit deficiencies during their inspections or
               identified the conditions but did not report the units as being in noncompliance.



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               As a result, the Authority paid $31,474 in ineligible subsidies for the 8 units, and
               we estimate the Authority will pay housing assistance payments of more than
               $1.14 million for units in material noncompliance with housing quality standards.

               The Authority paid $10,393 in excess housing assistance payments for 5 of 22
               tenants housed in units larger than justified by the families’ composition. The
               improper voucher size occurred because the Authority did not always follow
               requirements to ensure that tenants are only issued Section 8 vouchers for the unit
               size authorized by their family composition.


    What We Recommend


               We recommend that the director of the Office of Public Housing require the
               Authority to abate Section 8 subsidies or terminate HAP contracts on all units that
               do not meet standards if the violations detected by our inspections are not
               corrected in a timely manner. The director should also require the Authority to
               improve its controls over the inspection process to ensure that inspectors properly
               identify and report all housing quality standards violations in the units they
               inspect. The recommended action is needed to prevent more than $1.14 million
               from being spent on units with material housing quality standards violations. We
               further recommend that the director require the Authority to repay $31,474 from
               nonfederal funds for ineligible housing assistance payments it made for the eight
               units with material violations.

               We also recommend that the director of the Office of Public Housing require the
               Authority to reimburse its program from nonfederal funds $10,393 for excess
               housing assistance payments for five overhoused tenants plus any additional
               amount paid until corrective action is taken. The director should also require the
               Authority to establish controls to ensure initial determination of the correct
               voucher size and to adjust tenant vouchers in a timely manner to reflect reported
               changes in family composition. The director should require the Authority to issue
               the correct size voucher to each overhoused tenant and ensure their subsidy
               amounts are properly calculated.

               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.




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                                                 2
 Auditee’s Response


            We discussed the findings with the Authority and HUD officials during the audit.
            We provided a copy of the draft report to Authority officials on April 6, 2006, for
            their comments and discussed the report with the officials at the exit conference
            on April 14, 2006. The Authority provided its written comments to our draft
            report on April 26, 2006.

            The complete text of the Authority’s response, along with our evaluation of that
            response, can be found in appendix B of this report. The Authority also provided
            attachments with its response that are available for review upon request.




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                            TABLE OF CONTENTS


Background and Objectives                                                              5


Results of Audit
      Finding 1: The Authority Paid Section 8 Subsidies for Some Units That Did Not    6
                 Meet Housing Quality Standards

      Finding 2: The Authority Paid Excess Subsidies for Five Overhoused Tenants      11

Scope and Methodology                                                                 13

Internal Controls                                                                     15


Appendixes
   A. Schedule of Questioned Costs and Funds to Be Put to Better Use                  16
   B. Auditee Comments and OIG’s Evaluation                                           17




                                            4
                      BACKGROUND AND OBJECTIVES

 The Orlando Housing Authority (Authority) is a governmental agency created by the City of
 Orlando, Florida, in January 1938 pursuant to Chapter 421 of the Florida Statute. The
 Authority’s primary purpose is to develop, acquire, and operate safe, decent, sanitary, and
 affordable housing for low-income families in Orlando and Orange County, Florida. The U.S.
 Department of Housing and Urban Development’s (HUD) Jacksonville, Florida, Office of Public
 Housing is responsible for overseeing the Authority. The mayor of the City of Orlando appoints
 a seven-member board of commissioners to four-year terms to govern the Authority’s operations.
 The Authority’s executive director is responsible for its daily administration.

 The Authority administers approximately 2,909 Section 8 housing choice vouchers. The housing
 assistance payments for the month of August 2005 totaled more than $1.7 million.

 Our audit objectives were to determine whether Section 8 units met housing quality standards
 and whether tenant subsidies were limited to the amount allowed for the unit size authorized by
 the families’ composition.




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                                                5
                                           RESULTS OF AUDIT


Finding 1: The Authority Paid Section 8 Subsidies for Some Units That
           Did Not Meet Housing Quality Standards

We inspected 67 units and determined that 20 did not meet housing quality standards. Of the 20
units, 8 were in material noncompliance. As a result, the tenants lived in units that had one or
more material violations. This condition primarily occurred because the Authority’s inspectors
did not identify violations that existed at the time of inspection or identified the conditions but
did not report the units as being in noncompliance. The Authority paid $31,474 in ineligible
housing assistance payments for the 8 units with material violations. The 8 units represent 11.94
percent of the 67 units inspected. Based on this percentage, we estimate the Authority will pay
more than $1.14 million for units with material violations.



 Units Had Material Housing
 Quality Standards Violations


               We inspected 67 units with a HUD public housing inspector. The Authority’s
               lead inspector accompanied us on 40 of the inspections. The 8 units with one or
               more material violations involved conditions that the Authority either did not
               report or noted but did not report as noncompliance when it last inspected the
               units. We provided the Authority with a copy of our inspection report for each of
               the 20 failed units for consideration and initiation of corrective action. The
               following table summarizes the deficiencies for the 8 units with material
               violations.

                                           Type of material violations
                 Sample                                                                 Violations
                  item        Electrical                                   Vermin           not           Total
                 number        hazards      Structural    Appliance      infestation   classified as   deficiencies
                                                             s                           material

                    14            2            1*           1*             1            1                6
                    27            1            2*                                       1                4
                    62            1*           1                                        1                3
                    83            2*           1                                                         3
                    47            1            1*                                       1                3
                    12            1*           1*                                                        2
                    13            1*                                                    1                2
                    25            1*                                                                     1
                Total             10           7             1             1            5               24
              * This category includes one or more violations that existed when the Authority inspected the unit.



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            We determined the eight units with material violations by assessing factors such
            as (a) deficiencies that had existed for an extended period, (b) deficiencies noted
            in prior inspections but not corrected, and (c) deferred maintenance. We
            determined that eight tenants lived in units that had one or more material
            violations. The remaining 12 units involved violations that required corrective
            action, but we did not determine them to be material violations primarily because
            they occurred after the Authority’s last inspection.


Electrical Hazards Were the
Most Prominent Violations

            Electrical hazards were the most prominent violations detected during our
            inspections. Each of the eight units had one or more electrical hazards. The
            hazards included conditions such as exposed wiring and inoperable smoke
            detectors. For instance, we found exposed wiring in some units where children
            resided, including one house with exposed wiring at the light switch and breaker
            box in the utility/laundry room.




                    Exposed breaker box wires                      Exposed light switch wire

            The above conditions existed at the time of the Authority’s most recent unit
            inspection, but the inspector did not identify and report the violations.


Structural Violations Were
Identified

            We identified one or more structural violations at six of the eight units that failed
            with material noncompliance. For instance, we identified one unit with cracked
            carport ceiling support beams and another unit with damaged doors.




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                    First cracked carport beam          Second cracked carport beam




                                     Damaged exterior door

           The Authority identified the two cracked carport support beams during its
           inspection but passed the unit. The cracked beams could result in roof collapse.
           In the other instance, the Authority did not identify the damaged door. The door
           was not airtight and allowed air and/or moisture to enter the unit.

           Federal regulations at 24 CFR [Code of Federal Regulations] 982.401(a)(3) state
           that all program housing must meet housing quality standards performance
           requirements, both at commencement of assisted occupancy and throughout the
           assisted tenancy.




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                                                 8
The Authority Needs to Ensure
That Inspectors Identify and
Report All Housing Quality
Violations

             The Authority should improve controls to ensure that its inspectors identify and
             report all housing quality standards violations. The Authority’s inspection
             procedures appeared adequate, and if the inspectors had fully followed those
             procedures, they should have identified and reported the material violations for
             the eight units discussed above. We attribute the missed violations to the
             inspectors’ failure to properly review, consider, and report all housing quality
             standards violations for the units they inspected. None of the 67 inspected units
             appeared to be dilapidated, although eight units had one or more material
             violations. The Authority’s inspectors properly identified and reported the
             condition of 59, or 88 percent, of the 67 units we inspected.


The Authority Has Begun to
Take Corrective Actions


             The Authority requested the landlords and tenants to correct the deficiencies we
             reported for the 20 failed units. The Authority’s records for the eight units with
             material violations show that (a) four landlords completed the requested
             corrective action, (b) three landlords were provided abatement notices due to their
             failure to complete the requested repairs, and (c) one tenant moved before the
             Authority could determine whether the landlords completed the requested repairs.


Conclusion


             The Authority paid $31,474 in ineligible housing assistance payments for the
             eight units with material violations. The eight units represent 11.94 percent of the
             67 units inspected. Based on this inspection result, we estimate the Authority will
             pay more than $1.14 million for units with material violations in addition to the
             ineligible amount. As a result, some tenants lived in units that were not decent,
             safe, and sanitary, and the Authority made ineligible housing assistance payments
             that could have been used to assist other eligible tenants.




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                                                  9
Recommendations


           We recommend that the director of the Office of Public Housing require the
           Authority to

           1A.      Abate Section 8 subsidies or terminate the HAP contracts on all units that
                    do not meet standards if the violations detected by our inspection are not
                    corrected in a timely manner.

           1B.      Develop and implement improved controls to ensure that each inspector
                    properly reviews, considers, and reports all housing quality standards
                    violations for the units inspected and to prevent more than $1.14 million
                    from being spent on units that are in material noncompliance with
                    standards.

           1C.      Repay $31,474 to its Section 8 program from nonfederal funds for housing
                    assistance payments made for the eight units with material violations.




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                                                 10
Finding 2: The Authority Paid Excess Subsidies for Five Overhoused
           Tenants
The Authority generally issued the proper Section 8 voucher size to its tenants. However, it
issued vouchers for 36 tenants for units larger than justified by their family composition
(overhoused). As a result, the Authority paid $10,393 in ineligible costs for excessive subsidies
paid on behalf of five tenants and increased the potential for excessive subsidy payments for an
additional 31 overhoused tenants. These conditions occurred because the Authority did not
consistently comply with requirements designed to prevent the issuance of Section 8 vouchers
for units larger than justified by a family’s composition and the associated risk of excessive
subsidy payments.



 Improper Voucher Size
 Results in Excessive Subsidy
 Payments



               We conducted a computer assessment of the Authority’s 2,909 Section 8 vouchers
               and identified 53 tenants who appeared to be overhoused. We reviewed the files
               for 22 tenants and determined that the Authority paid $10,393 in excessive
               subsidies on behalf of 5 of the 22 tenants. In two cases, the Authority issued the
               wrong voucher size from the beginning of the tenants’ participation in the Section
               8 program and did not detect the error. In the other three cases, the Authority
               failed to downsize the voucher at the next annual recertification to reflect reported
               changes in the families’ composition. As a result, the Authority continued to pay
               subsidies based on an incorrect payment standard and/or utility allowance for
               units larger than justified by the families’ composition.

               Our computer assessment of the remaining 31 units showed potential for
               excessive subsidy payments because the tenants were issued or retained larger
               vouchers than appeared justified by their family composition. However, the
               Authority did not make excessive subsidy payments on behalf of these tenants
               because their low unit rent resulted in subsidies that were less than the amounts
               authorized for the correct unit size.

               Federal regulations at 24 CFR [Code of Federal Regulations] 982.402(b)(1)
               provide that when determining unit size, the subsidy standards must provide for
               the smallest number of bedrooms needed to house a family without overcrowding.
               The regulations at 24 CFR 982.402 (c) provide that the payment standard for a
               family shall be the lower of (a) the payment standard amount for the family unit
               size or (b) the payment standard amount for the unit size of the unit rented by the
               family.


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                                                    11
          The Authority did not consistently comply with requirements designed to prevent
          the issuance of Section 8 vouchers for units larger than justified by a family’s
          composition and the associated risk of excessive subsidy payments. This
          noncompliance includes the Authority’s failure to initially determine the correct
          voucher size and to adjust tenant vouchers in a timely manner to reflect reported
          changes in family composition. The $10,393 paid for excessive subsidies reduced
          Section 8 assistance available through the Authority for other families to obtain
          decent, safe, and sanitary housing.


Recommendations


          We recommend that the director of the Office of Public Housing require the
          Authority to

          2A.     Reimburse its Section 8 program $10,393 for excess housing assistance
                  payments from nonfederal funds plus any additional amount up to the
                  point that corrective action is completed.

          2B.     Develop controls to ensure initial determination of the correct voucher size
                  and to adjust tenant vouchers in a timely manner to reflect reported
                  changes in family composition.

          2C.     Adjust, where applicable, the vouchers for the 36 tenants to reflect the
                  correct voucher size authorized by the families’ composition.




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                                               12
                         SCOPE AND METHODOLOGY

To accomplish our audit objective, we

       •   Reviewed applicable laws, regulations, and other HUD program requirements.

       •   Reviewed the Authority’s Section 8 policies and procedures and administrative plan.

       •   Interviewed Jacksonville, Florida, Office of Public Housing program officials and the
           Authority’s management and staff.

       •   Reviewed the Authority’s fiscal year 2004 independent public accountant report and
           HUD program monitoring reviews.

       •   Obtained a download of the Authority’s Section 8 housing stock for the Housing
           Choice Voucher program as of August 31, 2005. We then tested the reliability and
           validity of the data. Based on the tests, we assessed the data as sufficiently reliable,
           given our objective and intended use.

       •   Assessed the files for 22 of 53 tenants identified through computer analysis as
           possibly housed in units larger than justified by their family composition. We
           recalculated the housing assistance to determine whether this condition resulted in
           excessive subsidy payments. When making the calculations, we relied on the income
           and deductions documented in the Authority’s files. We did not reverify or confirm
           the accuracy of the income and deductions.

We obtained a listing of the Authority’s current units from the housing assistance payment
register as of August 31, 2005. We adjusted the listing to exclude units not located in the
Orlando area, such as portable units for tenants with housing choice vouchers issued by the
Orlando Housing Authority but who now live in the jurisdiction of other housing authorities.
The Authority had 2,909 tenants as of August 31, 2005. We used a statistical software program
to select a random sample from the 2,909 tenants. The software returned a sample size of 67
units with a random start based on a 90 percent confidence level, 10 percent precision level, and
50 percent expected error rate. We selected an additional 67 units to be used for replacements if
needed.

We inspected 67 units with a HUD inspector from the Jacksonville, Florida, Office of Public
Housing to determine whether the units met housing quality standards. The Authority’s lead
inspector accompanied us on 40 inspections. We performed the inspections between October 31
and December 20, 2005. We selected 16 of the replacement units (68 through 83) because 12
units were vacant by the time of our inspection, two units were no longer being subsidized, and
two tenants were not home.

We identified the eight units with material violations after giving consideration to factors such as
(a) deficiencies that had existed for an extended period of time, (b) deficiencies noted in a prior

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inspection but not corrected, and/or (c) deferred maintenance that consistently fails the unit. We
further based our assessment on prior Authority inspection reports, tenant comments, and our
observation and judgment based on our unit inspections. Projecting the results of the eight failed
units with material violations in our statistical sample to the population indicates

       •   The lower limit is 5.50 percent x 2,909 units = 159 units not meeting housing quality
           standards.

       •   The point estimate is 11.94 percent x 2,909 units = 348 units not meeting housing
           quality standards.

       •   The upper limit is 18.38 percent x 2,909 units = 534 units not meeting housing quality
           standards.

The Authority’s August 31, 2005, housing assistance payments documentation showed that the
average monthly housing assistance payment was $601. Using the lower limit of the estimate of
the number of units and the average monthly housing assistance payment, we estimated that the
Authority will annually spend at least $1,146,708 (159 units x $601 average payment x 12
months) for units that are in material noncompliance with housing quality standards. This
estimate is presented solely to demonstrate the annual amount of Section 8 funds that could be
put to better use on decent, safe and sanitary housing if the Authority implements our
recommendation. While these benefits would recur indefinitely, we were conservative in our
approach and only included the initial year in our estimate. We also considered that (1) the
Authority did not identify many of the past conditions during its most recent inspections, (2) the
units would not be scheduled for another inspection for another year under normal
circumstances, and (3) it would take the Authority at least a year to complete all inspections
under an improved inspection process. We calculated $31,474 in ineligible subsidies for the
units in material noncompliance by considering among other factors, the length of time the
deficiencies existed and a 30-day period for responsible parties to correct the deficiencies.

The audit generally covered the period of April 1, 2003, through August 31, 2005. We extended
the period as needed to accomplish our objectives. We conducted our fieldwork from October
through December 2005 at HUD, the Authority, and the homes of various tenants located within
the Authority’s jurisdiction.

We conducted the audit in accordance with generally accepted government auditing standards.




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                                                14
                               INTERNAL CONTROLS


Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following objectives are being 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
missions, 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:

       •   Controls over program operations,
       •   Controls over the validity and reliability of data,
       •   Controls over compliance with laws and regulations, and
       •   Controls over the safeguarding of resources.


We assessed the relevant controls identified above.

A significant 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.

 Significant Weaknesses


Based on our review, we believe that the following item is a significant weakness:

       •   The Authority needs to improve controls to ensure that its inspectors properly review,
           consider, and report all housing quality standards violations for the units they inspect
           (finding 1).




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                                                15
                                      APPENDIXES

Appendix A
                   SCHEDULE OF QUESTIONED COSTS
                 AND FUNDS TO BE PUT TO BETTER USE



                                                       Funds to be put
     Recommendation               Ineligible 1/        to better use 2/
           1B                                            $1,146,708

           1C                     $31,474

           2A                     $10,393                ________

         Total                    $41,867                $1,146,708


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/     “Funds to be put to better use” are estimates of amounts that could be used more
       efficiently if an Office of Inspector General (OIG) recommendation is implemented.
       This includes reductions in outlays, deobligation of funds, withdrawal of interest subsidy
       costs, costs not incurred by implementing recommended improvements, avoidance of
       unnecessary expenditures noted in preaward reviews, and any other savings which are
       specifically identified. In this instance, if the Agency implements our recommendation, it
       will cease to incur Section 8 costs for units that are not “decent, safe and sanitary,” and,
       instead will expend those funds for units that meet HUD’s standards. Once the Agency
       successfully improves its controls, this will be a recurring benefit. Our estimate reflects
       only the initial year of these recurring benefits.




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                                                  16
Appendix B

                AUDITEE COMMENTS AND OIG’S EVALUATION


Ref to OIG Evaluation           Auditee Comments




Comment 1


Comment 2




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Comment 3




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Comment 1




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                      19
                    OIG Evaluation of Auditee Comments




Comment 4




Comment 5



Comment 5




Comment 2




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Comment 6




Comment 2
Comment 6




Comment 4
Comment 7




Comment 4
Comment 8




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Comment 4
Comment 9




Comment 4
Comment 10




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Comment 4
Comment 11




Comment 4
Comment 12




Comment 4
Comment 13




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Comment 4
Comment 14




Comment 4
Comment 15




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Comment 4




Comment 2




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Comment 3




Comment 1
Comment 6




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Comment 16




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                    30
Comment 16




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Comment 17




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                    35
Comment 16




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                    37
Comment 16




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Comment 18




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                    41
Comment 18




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                    43
Comment 18




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                    45
Comment 19




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                    47
                         OIG Evaluation of Auditee Comments


Comment 1   The Authority commented that our report did not acknowledge the hurricanes that
            occurred and the impact they caused. We recognize the hurricane’s general
            impact as noted in the Authority’s written response. However, the audit
            objectives addressed the Authority’s housing quality standard inspections and
            whether the Authority issued the correct voucher size to section 8 tenants. The
            Authority provided no support that hurricane related issues substantially
            hampered its recent ability to perform duties specifically related to the audit
            objectives.

Comment 2   The Authority commented that our protocol was fundamentally flawed and led to
            unsupportable conclusions. They also commented that too much time elapsed
            between their inspection and our audit (four to eleven months) and the conditions
            noted by the OIG were from normal wear and tear and/or tenant caused damage
            versus by an error or omission of the OHA’s inspections.

            We planned and conducted the audit according to generally accepted government
            auditing standards. We requested the Authority’s written response and adjusted
            the report where appropriate. For instance, see comments 3, 4, 14, and 16 below.
            The adjustments did not materially change our conclusions. We disagree with the
            Authority’s blanket assertion that we reached unsupported conclusions. The
            conditions noted by the OIG, which were attributed to OHA inspections, are
            valid. Our methodology included interviewing tenants and owners to supplement
            our physical observations concerning the violations and how long they existed.

Comment 3   We reassessed and concur with the Authority’s position that for overhoused tenants
            the new family unit size must be used to determine the payment standard amount
            beginning at the family’s first regular re-examination following the change in the
            family size. We revised the report accordingly.

Comment 4   The Authority disagreed with our comment that the “condition primarily occurred
            because the Authority’s inspectors did not identify violations that existed at the
            time of inspection or identified the conditions but did not report the units as being
            in noncompliance.” We clarified the report to identify the units with one or more
            material violations that existed at the time of the Authority’s inspection. Our
            conclusions were based on observations we made during the unit inspections,
            interviews with the tenants, interviews with the owners, and review of the
            Authority’s files. The Authority cited disagreement based on their consideration
            of similar information. We maintain the position cited in the report.

Comment 5   The Authority provided no support for its claim that, “The Section 8 Participants’
            signed statements in the inspection files document that the conditions identified
            by the OIG did not exist at the time of the OHA inspection”. The Authority
            comment was made in reference to the tenants response to two questions asked by


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              the inspector and recorded on Inspection Form HUD-52580, page 19, section D.
              The questions asked, (a) does the owner make repairs when asked, and (b) is there
              anything else you want to tell us? The absence of a tenant complaint against the
              owner or the tenant voicing other concerns to the inspector does not support the
              Authority’s claim that the tenants’ signed statement documents that the OIG
              claimed conditions did not exist. We maintain the accuracy of our conclusion
              based on our inspection results and discussions with the tenants and with the
              owners.

Comment 6     The Authority commented that between the times they inspected the units and our
              audit, three category 3 devastating hurricanes occurred (Charley, Frances, and
              Jeanne). The Authority’s claim is not correct. Hurricanes Charlie, Frances, and
              Jeanne occurred between August and September 2004. The Authority conducted
              its inspections between December 2004 and October 2005. Our audit began in
              August 2005 and we conducted our inspections from October 31 to December 20,
              2005.

Comment 7     Sample item number 14 - The Authority’s inspection report showed that one
              burner was not working on the stove. The violation should have caused the unit
              to fail, but the Authority’s inspector passed the unit. By the time we inspected the
              unit two burners were not working. At the exit conference, Authority officials
              agreed that their inspector should have failed this unit.

Comment 8     Sample item number 27 - The Authority questioned the accuracy of the owner’s
              statement regarding the date she purchased the unit and the conditions we noted
              during the inspection. We had no reason to doubt what the owner told us. The
              results of our inspections were valid. The Authority communicated our inspection
              results to the owner and obtained corrective action.

Comment 9     Sample item number 62 - Based on an assessment of the Authority’s response we
              revised the report to omit one of the two reported electrical violations. The
              Authority communicated the results of our inspection to the owner and obtained
              corrective action.

Comment 10 Sample item number 83 - The Authority’s comments seek to dismiss the validity
           of our inspection results based on the absence of a tenant complaint involving the
           conditions detected during our inspection. We do not know why the Authority’s
           files did not contain a copy of the complaint letter we obtained from the tenant.
           The results of our inspection are valid. The Authority communicated our
           inspection results to the owner followed by a notice of abatement because their
           reinspection showed the owner did not repair the conditions noted in our
           inspection report.

Comment 11 Sample item number 47 - The Authority’s comment indicates the tenant
           comments to them matched what the tenant told us. However, the Authority
           dismissed the validity of the tenant’s comments based on the absence of a tenant

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              complaint. The results of our inspection are valid. The Authority communicated
              our inspection results to the owner followed by a notice of abatement because
              their reinspection showed the owner did not repair the condition noted in our
              inspection report.

Comment 12 Sample item number 12 - The Authority’s comments provided no information that
           warranted a revision to our conclusion. The results of our inspection are valid.
           The Authority communicated the results of our inspection to the owner and
           obtained corrective action.

Comment 13 Sample item number 13 - The Authority questioned the accuracy of what the
           tenant told us when we inspected the unit. We had no reason to doubt what the
           tenant told us. The results of our inspection are valid. The Authority
           communicated our inspection results to the owner and obtained corrective action.

Comment 14 Sample item number 67 – We deleted this unit from the report based on
           consideration of the Authority’s comments and their reinspection of the unit.

Comment 15 Sample item number 25 - The Authority’s comments acknowledged uncertainty
           about whether its inspector carefully examined the unit for the item detected by
           our inspection. The Authority stated that it would provide additional training to
           its inspectors concerning this type electrical condition.

Comment 16 We assessed and agree with the Authority’s written comments for clients 4561,
           4137, 1070 and 3878. We revised finding 2 to remove reference to the four
           tenants.

Comment 17 Clients 5980 - The Authority comment indicates they did not adjust the tenants
           voucher size because the change in family composition was not reported until
           3/5/04. The Authority’s comments show the annual recertification process started
           on 1/1/04 with an effective completion date of 4/1/04. The Authority provided
           documents that show the actual change in composition occurred in February 2004.
           The Regulations, 24 CFR 982.505c(5) require adjustment to the unit size
           beginning at the family’s first regular reexamination following the change in
           family unit size. Therefore, the position cited in the finding is consistent with the
           regulations that required the adjustment effective with the 4/1/04 annual
           reexamination.

Comment 18 Clients 25529, 27196, and 31308 - The Authority commented that due to the
           recent hurricanes they allowed the tenants to remain in the units they occupied
           rather than have households seeking new housing. The tenant file we examined
           did not document the reason cited in the Authority’s written comment for not
           making the changes. We did not revise the report because the basis for the
           adjustments are regulatory (24 CFR 982.505c(5)).


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Comment 19 Client 36608 - The Authority indicated that the client ported in from another PHA
           with a 3-bedroom voucher for two disabled people. It also indicated that both
           family members are disabled and a medical letter in the file triggered reasonable
           accommodation. We reviewed the tenant file and determined that it contained a
           handwritten note from the initial PHA requesting the Authority issue a 3-bedroom
           voucher due to the clients’ disabilities. The handwritten note was not an adequate
           substitute for the required medical documentation. The Authority’s written
           comment states, “At the reexam 07/01/06, the client will be issued a voucher that
           is appropriate for their family size. The Authority’s comment provided no
           information that justified a revision to the position cited in the finding.




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