AUDIT REPORT
Review of Worcester Housing Authority, Worcester, MA
Identified $1.9 million of its Public Housing Operating Funds
Used for Non-program Purposes
2006-BO-1002
November 29, 2005
OFFICE OF AUDIT, REGION 1
Boston, Massachusetts
Table of Contents
Issue Date
November 29, 2005
Audit Report Number
2006-BO-1002
TO: Donna Ayala, Director, Office of Public Housing, Boston Hub, 1APH
FROM: John Dvorak, Regional Inspector General for Audit, 1AGA
SUBJECT: Review of Worcester Housing Authority, Worcester, MA Identified $1.9
Million of its Public Housing Operating Funds Used for Non-program
Purposes
HIGHLIGHTS
What We Audited and Why
We reviewed the Housing Choice Voucher program and the Public Housing
Operating Fund program at the Worcester Housing Authority (Authority). This
audit was conducted as part of our fiscal year 2005 annual audit plan. Our
objectives were to determine whether the Authority improperly used Federal
funds for expenses of its State programs, and whether it properly allocated salary
and other expenses to its Housing Choice Voucher program and Public Housing
Operating Fund program.
What We Found
The Authority did not administer its federal funds in compliance with the financial
provisions of its annual contributions contracts. Specifically, the Authority used its
Public Housing Operating Funds to pay expenditures for state-subsidized housing
programs and other federal programs, and did not properly allocate salary and
benefit expenses to its Housing Choice Voucher program and Public Housing
Operating Fund program.
Table of Contents
These conditions occurred because the Authority did not follow the internal controls
that it established to ensure compliance with its annual contributions contracts and
HUD regulations. The executive director stated that he made a decision to loan
Public Housing Operating Fund operating reserves to pay state expenses until the
state reimbursed the Authority for its expenses. Also, the salary and benefits were
not charged to the programs using a supported basis to ensure that only reasonable
costs were charged for the operation of the programs. As a result, the Authority did
not have more than $1.9 million available for its Public Housing Operating Fund
program. Additionally, without an adequate basis, the Authority could not support
the salary and benefits expenses charged to its Housing Choice Voucher and Public
Housing Operating Fund programs.
What We Recommend
We recommend that the director of the Office of Public Housing require the
Authority to
• Cease the practice of using Public Housing Operating Funds to pay for
nonprogram costs, such as the $1.9 million1 used from and owed to the Public
Housing Operating Fund program as of August 31, 2005.
• Reimburse its revolving fund the amounts owed by its programs on a monthly
basis.
• Conduct a time study to determine the appropriate allocation of salaries and
benefits for its federal programs.
• Develop and implement a HUD-approved cost allocation plan for salaries and
employee benefits, and adjust its fiscal year 2006 accounting records
accordingly.
For each recommendation in the body of the report 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
The complete text of the auditee’s response, along with our evaluation of that
response, can be found in appendix B of this report.
1
The Authority repaid $1.2 million in August 2005 and another $1.2 million in October 2005. Both payments
went into the revolving fund and were transferred to the Public Housing Operating Fund program in these same
months.
Table of Contents 2
TABLE OF CONTENTS
Background and Objectives 4
Results of Audit
Finding 1: The Authority Inappropriately Used $1.9 Million in Federal Funds 5
Finding 2: The Authority Did Not Properly Allocate Expenses to Federal 9
Programs
Scope and Methodology 13
Internal Controls 14
Appendixes
A. Schedule of Questioned Costs and Funds to Be Put to Better Use 15
B. Auditee Comments and OIG’s Evaluation 16
3
BACKGROUND AND OBJECTIVES
The United States Housing Act of 1937 established the first federal framework for government-
owned affordable housing. This act also authorized public housing as the nation’s primary
vehicle for providing jobs and building and providing subsidized housing through the
Department of Housing and Urban Development (HUD). HUD disperses funds to public
housing agencies under annual contribution contracts to provide subsidy payments or housing
assistance payments for participating low-income families.
In addition, the United States Housing Act of 1937 as amended by the Quality Housing and
Work Responsibility Act of 1998 authorizes operating subsidies for public housing agencies
administering HUD low-income housing programs. HUD provides annual operating subsidies,
through the Public Housing Operating Fund program, to help public housing agencies pay some
of the cost of operating and maintaining public housing units. Operating subsidies are essential
for public housing agencies to provide cost-effective, decent, safe, and affordable dwellings for
low-income and very low-income tenants who pay no more than 30 percent of their adjusted
income for rent.
The Quality Housing and Work Responsibility Act of 1998 created the Housing Choice Voucher
program. The Housing Choice Voucher program allows public housing authorities to pay HUD
subsidies directly to the housing owners on behalf of the assisted family.
Through annual contributions contracts, HUD contracts with the Worcester Housing Authority
(Authority) for the administration and management of 2,074 low-income units, 1,798 housing
choice vouchers and 39 moderate rehabilitation vouchers.2 The annual contributions contracts
require the Authority to follow appropriations laws, public housing notices, and the Authority’s
administrative plan. The Authority provides these housing assistance subsidies to assist families
with housing through its leases with property owners and its agreements with other housing
authorities. The Authority also receives a fee to administer the Housing Choice Voucher
program.
Our overall audit objectives were to determine whether the Authority improperly used federal
funds to pay expenses of its state programs in violation of the financial provisions of its annual
contributions contracts and whether it properly allocated salary and other expenses to its Housing
Choice Voucher program and Public Housing Operating Fund programs.
_____________________
2
The Authority administers 1,837 vouchers in total, which includes the 1,798 Housing Choice Vouchers and 39
Moderate Rehabilitation program vouchers.
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RESULTS OF AUDIT
Finding 1: The Authority Inappropriately Used $1.9 Million in
Federal Funds
The Authority did not comply with its annual contributions contracts when it used Public
Housing Operating Fund program funds to pay for nonprogram expenses. These program funds
may only be withdrawn for Public Housing Operating Fund program purposes. However, the
Authority inappropriately used these federal funds to pay for expenses of its state funded programs
and other federal programs. The executive director stated he decided to loan Public Housing
Operating Fund operating reserves for state expenses because the state did not reimburse the
Authority timely for state program expenses. As a result, the Authority did not have more than $1.9
million available for its Public Housing Operating Fund program as of August 31, 2005.
The Authority Used Federal
Funds Inappropriately
The Authority’s consolidated annual contributions contracts with HUD require it to
maintain records that identify the source and application of funds. These records are
required to allow HUD to determine whether the Authority has expended funds
appropriately. The Authority uses a series of fund accounts to track the source and
use of funds for programs such as the Public Housing Operating Fund program
(low-rent program). The funds received for all federal programs flow through the
program’s general ledger account into the Authority’s revolving fund, from which
program expenditures are paid. However, federal program funds were not always
used to pay expenditures of the funded federal program. We verified that the
Authority transferred Public Housing Operating Fund program funds to the
revolving fund to pay for expenses of state and other federal programs.
The Authority generally repaid the Public Housing Operating Fund program on a
quarterly basis by transferring funds from the state and other programs through the
revolving fund. However, the Authority indicated that it loaned Public Housing
Operating Fund operating reserves to the revolving fund for state program expenses
until the state paid the Authority. On July 1, 2005, the state confirmed that it owed
the Authority approximately $1.5 million.
The revolving fund showed that the Public Housing Operating Fund was owed
$1,943,662 on August 31, 2005. When we asked for the breakout of the $1,943,662
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the Authority provided a reconciliation showing the amounts owed by programs.
Programs Owing Amount Owing Programs Owed Amount Owed
Public Housing
State programs $1,622,851 $1,943,662
Operating Fund
Housing Choice Advances to
$582,292 $300,808
Voucher program Revolving fund
Other federal
$39,327
programs
Subtotal $2,244,470 Subtotal $2,244,470
The Authority attributes the $300,808 difference at August 31, 2005 to advances
from programs to the revolving fund. Additionally, the Authority attributed the
amount owed by the Housing Choice Voucher program and other federal programs a
result of the Authority’s procedures to reimburse its revolving fund quarterly instead
of monthly.
Also, as the chart below shows, the Authority’s revolving fund routinely owed the
Public Housing Operating Fund program and the amount owed changed each month.
Amount that revolving fund owed to Public Housing
Operating Fund program
$3,500,000
$3,000,000
$2,500,000
Dollars
$2,000,000
$1,500,000
$1,000,000
$500,000
$-
0 03 0 03 0 03 0 04 0 04 0 04 0 04 0 05 0 05 0 05
r-2 l -2
ct
-2 n -2 r-2 l -2
ct
-2 n -2 r-2 l -2
Ap Ju O Ja Ap Ju O Ja Ap Ju
Month and year
Authority Repaid Public
Housing Operating Fund
program
The state paid the Authority $1.2 million in August 2005 and another $1.2 million in
October 2005. Both payments went into the revolving fund and then were
transferred to the Public Housing Operating Fund program in these same months. In
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September 2005, the Authority reimbursed the revolving fund the $582,292 owed by
the Housing Choice Voucher program and the $39,327 owed by other federal
programs.
Internal Controls Not Followed
The Authority’s improper use of federal funds occurred because it did not follow
the internal controls it established to ensure compliance with the financial
provisions of its annual contributions contracts for its federal programs. The
Authority’s executive director advised us that he made a decision to loan Public
Housing Operating Program reserve funds to cover state expenses due to a failure
of the state to provide sufficient funding for the state-subsidized housing
programs in a timely manner. As a result, the Authority’s use of these funds
violated the provisions in its annual contributions contract with HUD.
Additionally, it attributed the amounts owed by other programs, including the
Housing Choice Voucher program, a result of its policy to reimburse the
revolving fund on a quarterly basis, as opposed to a monthly basis.
Conclusion
The Authority did not follow internal controls that prevented it from using federal
funds to pay nonprogram expenditures. The Authority’s executive director decided
to use Public Housing Operating program funds for nonprogram purposes, which
was an inappropriate use of more than $1.9 million in federal funds, and left its
Public Housing Operating Fund program less funding available. The Authority
repaid $1.2 million in August 2005 and another $1.2 million in October 2005 to its
revolving fund and then transferred funds to the Public Housing Operating Fund
program in these same months.
Recommendations
We recommend that the director of the Office of Public Housing require the
Authority to
1A. Cease the practice of using Public Housing Operating Funds to pay for
nonprogram costs, such as the $1,943,662 that was owed as of August 31,
2005.
1B. Submit monthly accounting reports with supporting documentation to HUD
for monitoring.
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1C. Reimburse its revolving fund the amounts owed by its programs on a
monthly basis, as opposed to a quarterly basis.
We recommend that the director of the Office of Public Housing
1D. Take appropriate administrative actions against Authority officials for the
improper use of federal funds.
Table of Contents 8
Finding 2: The Authority Did Not Properly Allocate Expenses to
Federal Programs
The Authority did not properly allocate salaries and employee benefits to the proper programs
during fiscal years 2003, 2004, and 2005. We estimate that the Authority overallocated
$2,363,161 in administrative and maintenance salaries and employee benefits3 to the Public
Housing Operating Fund program and underallocated $672,039 to its Housing Choice Voucher
program. This occurred because the Authority did not have a supportable basis for the plan
governing the allocation of costs to the benefiting programs, but adjusted its cost allocations
according to program funding levels. The Authority attributed the inappropriate allocation to the
Commonwealth of Massachusetts not providing sufficient funding to operate the Authority’s
state-subsidized programs. As a result, the Authority had less funding available to operate its
Public Housing Operating Fund program.
Authority’s Unsupported Basis
for Allocating Costs
The Authority did not have a documented basis for the salary percentages
allocated to its programs. The Authority acknowledged that the allocated salaries
based on those percentages were not supported with time studies or other
measurable basis. The Authority indicated that it used the same plan for many
years—including those years when HUD required all Authorities to submit
operating budgets with allocation plans for HUD’s approval. During our audit
period, this requirement was no longer in effect. The Authority acknowledged
that the Public Housing Operating Fund program was allocated more in salary
costs due to salary caps imposed by the state.4
The Authority Improperly
Allocated Expenses in its Fiscal
Years 2003 to 2005
We estimate that the Authority overallocated $2,363,161 in administrative
salaries, ordinary maintenance salaries and employee benefits to the Public
Housing Operating Fund program, of which $672,039 was underallocated to the
Housing Choice Voucher program and $1,691,122 was underallocated to state
programs. The tables below summarize the total estimated amounts
3
Employee benefits included retirement benefits, unemployment taxes, health insurance, and Medicare taxes.
4
The Commonwealth of Massachusetts requires each housing authority that receives state-subsidized housing funds
to operate within a maximum budget provided by the state.
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inappropriately allocated to the Public Housing Operating Fund and Housing
Choice Voucher programs by fiscal year under the Authority’s allocation plan or
methodology.
Public Housing Operating Fund program
Fiscal year Fiscal year Fiscal year
Total
2003 2004 2005
Description
Administrative
$410,205 $315,067 $287,144 $1,012,416
salaries
Ordinary
maintenance $148,511 $114,918 $113,794 $377,223
salaries
Employee
$408,712 $284,338 $280,472 $973,522
benefits
Totals $967,428 $714,323 $681,410 $2,363,161
Housing Choice Voucher program
Fiscal year Fiscal year Fiscal year Total
Description
2003 2004 2005
Administrative ($436,458)
($173,612) ($163,327) ($99,519)
salaries
Ordinary $0
maintenance $0 $0 $0
salaries
Employee ($235,581)
($75,319) ($103,209) ($57,053)
benefits
Totals ($248,931) ($266,536) ($156,572) ($672,039)
For all departments except the Authority’s Admissions Department, we used a
straight unit allocation methodology that divided the budgeted salaries by the
number of units of housing affected. This straight unit allocation methodology
was used because the Authority did not document the amount of time that each
employee spent on each of its programs. Absent time studies or other measurable
basis, a unit methodology would more appropriately allocate the costs to these
programs than the allocation method used by the Authority. Also during our
review of the salary expenses for the Admissions Department, we found that a
unit allocation methodology used for these costs would misallocate expenses to
the Housing Choice Voucher program when the Public Housing Operating Fund
program and state public housing programs benefitted from the expense. Staff in
the Admissions Department indicated that 50 percent of their time was spent on
the Public Housing Operating Fund program and 15 percent of their time was
spent on the Housing Choice Voucher program.
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The Authority also used a different method to allocate its employee benefits.5 For
employee benefits, the Authority divided the subtotal of budgeted salaries by
program into the total salaries for all programs to develop its allocation
percentages. The Authority then charged this percentage of the employee benefits
cost to each program. Since employee benefits are inherently tied to salaries, the
Authority should have used the same basis for employee benefits that it used for
salaries.
Incorrect Use of Public Housing
Operating Fund Program Units
in Allocation Plans
The Authority has other allocation plans for which the allocation basis was units.
For several of these plans, the Authority used 2,155 public housing units when the
authorized units were 2,074. The Authority should correct the number of units in
all of its allocation plans, adjust the unit-totals in its computer system, and correct
its accounting records accordingly for fiscal year 2006.
Conclusion
The Authority’s executive director made a decision to continue using the cost
allocation plan in place at the Authority when he was hired. However, the
Authority did not have a supportable basis that ensured costs were allocated and
charged to the benefiting programs. The Authority’s inappropriate allocations
removed more than an estimated $2.36 million or $787,720 annually from its
Public Housing Operating Fund program, of which $672,039 or $224,013
annually in salary expenses should have been allocated to its Housing Choice
Voucher program. Developing a cost allocation plan with a supportable basis
will save the Public Housing Operating Fund program $787,720 and appropriately
charge an additional $224,013 to the Housing Choice Voucher program in fiscal
year 2006.
Recommendations
We recommend that the director of the Office of Public Housing require the
Authority to
2A. Conduct a time study to determine the proper allocation of salaries and
benefits to the Housing Choice Voucher and Public Housing Operating
Fund programs.
5
The Authority did allocate medicare taxes based on its salary allocation plan.
Table of Contents 11
2B. Correct the number of units in all allocation plans to reflect the authorized
2,074 public Housing units.
2C. Develop, obtain HUD approval of, and implement an appropriate cost
allocation plan for salaries and employee benefits to ensure that only
necessary costs for administering the Public Housing Operating Fund and
Housing Choice Voucher programs are charged to the programs.
2D. Correct the Housing Choice Voucher and Public Housing Operating Fund
programs’ accounting records to record the appropriate salary and benefit
expenses attributable to the administration of these programs for fiscal
year 2006, which would result annually in funds put to better use of
$787,720 for the Public Housing Operating Fund program and $224,013
for the Housing Choice Voucher program
Table of Contents 12
SCOPE AND METHODOLOGY
We performed our review in accordance with generally accepted government auditing standards.
We conducted the audit between March and September 2005 and covered the period April 1,
2002, through March 31, 2005. The audit period was extended when necessary to meet our
objectives. To accomplish our audit objectives, we
• Reviewed the annual contributions contracts, Public and Indian housing notices,
the Authority’s administrative plans, the board of commissioners’ minutes, the
audited financial statements and the Authority’s procedures.
• Interviewed Authority officials and contractors about the financial controls, the
Housing Choice Voucher program controls, administrative procedures, and job
duties.
• Analyzed the Authority’s cost allocation plans, salaries, employee benefits, and
account records for fiscal years 2003, 2004, 2005, and 2006.
• Summarized results of our analyses.
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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
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:
• Controls over sources and uses of federal funds.
• Controls over tracking and reporting expenditures.
• Compliance with laws and regulations-Policies of management to reasonably
ensure that resource use is consistent with laws and regulations.
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 the following items are significant weaknesses:
• The Authority used federal funds inappropriately to pay expenditures for
state programs and other federal programs. (finding 1)
• The Authority inappropriately allocated expenses to federal programs.
(finding 2)
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APPENDICES
Appendix A
SCHEDULE OF QUESTIONED COSTS
AND FUNDS TO BE PUT TO BETTER USE
Recommendation Ineligible 1/ Unsupported 2/ Unreasonable or Funds to be put
number unnecessary 3/ to better use 4/
1A. $1,943,6626
2D. $1,011,733
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
polices or regulations.
2/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
or activity when we cannot determine eligibility at the time of audit. Unsupported costs
require a decision by HUD program officials. This decision, in addition to obtaining
supporting documentation, might involve a legal interpretation or clarification of
departmental policies and procedures.
3/ Unreasonable/unnecessary costs are those costs not generally recognized as ordinary,
prudent, relevant, and/or necessary within established practices. Unreasonable costs
exceed the costs that would be incurred by a prudent person in conducting a competitive
business.
4/ “Funds to be put to better use” are quantifiable savings that are anticipated to occur if an
Office of Inspector General 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.
__________________
6
The Authority repaid $1.2 million in August 2005 and another $1.2 million in October 2005. Both payments went
into the revolving fund and then were transferred to the Public Housing Operating Fund program in these same
months.
Table of Contents 15
Appendix B
AUDITEE COMMENTS AND OIG’S EVALUATION
Ref to OIG Evaluation Auditee Comments
Table of Contents 16
Ref to OIG Evaluation Auditee Comments
Comment 1
Comment 2
Comment 3
Comment 4
Table of Contents 17
Ref to OIG Evaluation Auditee Comments
Comment 5
Comment 6
Comment 7
Comment 8
Table of Contents 18
Ref to OIG Evaluation Auditee Comments
Comment 9
Comment 10
Comment 11
Comment 12
Comment 13
Comment 14
Comment 15
Table of Contents 19
Ref to OIG Evaluation Auditee Comments
Comment 16
Comment 17
Table of Contents 20
Ref to OIG Evaluation Auditee Comments
Comment 18
Comment 19
Table of Contents 21
OIG Evaluation of Auditee Comments
Comment 1 The audits conducted by the Authority’s Independent Public Accountant(s) should
have identified the issues of where federal funds were used for non-program
purposes.
Comment 2 Recommendation 1D recommends that HUD pursue administrative action
regarding the Authority’s inappropriate use of Federal funds.
Comment 3 The Authority violated its annual contributions contract when it withdrew Public
Housing Operating Funds operating reserves from the program to address cash
flow shortages in its other programs. The annual contributions contract states that
funds may be withdrawn only for specific purposes. These purposes are the
payment of the costs of development and operation of the projects under this
contract; the purchase of investment securities as approved by HUD; and such
other purposes specifically approved by HUD. HUD did not approve the use of
operating reserves for other Authority programs. Also, the usage of a revolving
fund is permitted by the annual contributions contract for the Public Housing
Operating Fund; however, amounts owed to the revolving fund by each program
should have been transferred to the revolving fund from each programs’ own
funds; and not used from the Public Housing Operating Fund program. While the
Authority reimbursed the operating reserves quarterly or when the funds became
available to the other programs, the usage of the fund was inappropriate.
Comment 4 We agree that using a unit approach does not take into account the amount of time
spent on federal programs; however, the Authority did not maintain its payroll
records to show the amount of time staff members worked on each of its
programs. Absent this data or a time study, a unit allocation was more
appropriate than methodology used by the Authority.
Comment 5 The statement that federal funds were not used to pay state expenses is incorrect.
The audit clearly showed that federal funds were used to pay state program
expenses, and the executive director made a statement that he made a decision to
use federal funds to pay state program expenses because the state had not
provided the state funding timely.
Comment 6 The Public Housing Operating Fund program was owed over $1.9 million by
other programs. This amount represents federal funds that were not available to
the Public Housing Operating Fund program, regardless of whether the Authority
had additional operating reserve funds available. The Authority is only allowed
to use Public Housing Operating Fund program funds and operating reserve funds
for its federal Public Housing Operating Fund program.
Comment 7 While the Authority has a systematic cost allocation plan that has been used for
years, this plan must have a documented methodology and measurable basis to the
Table of Contents 22
amounts charged to federal programs. Without a documented methodology such
as hours charged each pay period to each program and a measurable basis such as
a unit allocation, the Authority’s plan does not support that it appropriately
charged costs to the benefiting program.
OMB Circular A-87 requires that the Authority allocate costs to the benefiting
program. HUD has not required public housing authorities to submit operating
budgets for its approval since the 1990s. Even when HUD approved budgets, the
Authority retained the responsibility to document the basis for its charges to the
various programs.
Comment 8 We did not take exception to the use of budgeted salaries versus actual salaries in
the Authority’s allocation plan; instead, we noted how the Authority allocated
employee benefits. Employee benefits must follow the same allocation approach
as its salary allocations because employee salaries and employee benefits are
inherently tied to each other. The allocations for salaries and for employee
benefits should be consistent.
Comment 9 See Comment 3.
Comment 10 See Comment 1.
Comment 11 Federal operating reserve funds must be used for the program it was intended to
benefit, specifically the Public Housing Operating Fund program; and cannot be
used to cover cash flow shortages in other programs. Each program must run
independently and in accordance with each program’s contractual agreement.
Comment 12 The Authority tracks its sources and uses of funds; however, we did not find that
the Public Housing Operating Fund program was reimbursed in full by the
revolving fund during the April 2003 and August 2005 period reviewed. The line
chart on page 6 shows that the reimbursement changed each month but did not
reach zero at any point during that period.
Comment 13 We changed the report to recognize that the Authority reimbursed the operating
reserve in full at the end of our audit fieldwork.
Comment 14 See Comment 6.
Comment 15 We changed the report to reflect the separate payments of $1.2 million repaid in
August 2005 and another $1.2 million repaid in these same months. Both
payments went into the revolving fund and then were transferred to the Public
Housing Operating Fund program.
Comment 16 See Comment 4.
Comment 17 See Comment 8
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Comment 18 See Comment 7
Comment 19 Salary comparability studies are used to show that the total amount of a positions’
salary is appropriate for that job description in that locality. Comparability
studies do not show that the allocation of the salaries to specific programs is
appropriate. Since 1973, HUD has increased the quantity and diversity of the
programs that it offers to public housing authorities. The Authority has availed
itself of the opportunities in these programs by applying for and receiving grants
and contracts. With each new grant or contract, the Authority’s salary allocation
plan should change to reflect the new staff hired or existing staff allocated to
operate and manage each new grant or contract.
Table of Contents 24
Review of Worcester Housing Authority, Worcester, MA, Identified $1.9 Million of its Public Housing Operating Funds Used for Non-Program Purposes
Published by the Department of Housing and Urban Development, Office of Inspector General on 2005-11-29.
Below is a raw (and likely hideous) rendition of the original report. (PDF)