Issue Date
September 29, 2006
Audit Report Number
2006-CH-1019
TO: Thomas Marshall, Director of Public Housing Hub, 5DPH
FROM: Heath Wolfe, Regional Inspector General for Audit, 5AGA
SUBJECT: Lucas Metropolitan Housing Authority, Toledo, Ohio, Did Not Effectively
Operate Its Section 8 Housing Choice Voucher Program
HIGHLIGHTS
What We Audited and Why
We audited the Lucas Metropolitan Housing Authority’s (Authority) Section 8
Housing Choice Voucher program (program). The audit was part of the activities
in our fiscal year 2006 annual audit plan. We selected the Authority based upon a
risk analysis that identified it as having a high-risk program. Our objective was to
determine whether the Authority managed its program in accordance with the
U.S. Department of Housing and Urban Development’s (HUD) requirements.
What We Found
The Authority’s program administration regarding housing unit conditions and
required documentation to support housing assistance and utility allowance
payments was inadequate. Of the 62 housing units statistically selected for
inspection, 49 (79 percent) did not meet HUD’s housing quality standards, and 45
had 212 violations that existed at the time of the Authority’s previous inspections.
The 45 units had between 1 and 12 preexisting violations per unit. Based on our
statistical sample, we estimate that over the next year the Authority will pay more
than $1.3 million in housing assistance payments on units with material housing
quality standards violations.
The Authority failed to ensure that household files contained required
documentation to support its payment of housing assistance and utility
allowances. Of the 67 files statistically selected for review, 37 did not contain the
documentation required by HUD and the Authority’s program administrative
plan. The Authority also incorrectly calculated housing assistance payments,
resulting in nearly $23,000 in unsupported payments, more than $21,000 in
overpayments, and nearly $1,300 in underpayments from April 2004 through
March 2006.
The Authority had adequate procedures for abating units, conducted
recertifications on time, and initiated quality control reinspections in June 2005.
What We Recommend
We recommend that the director of HUD’s Cleveland Office of Public Housing
require the Authority to reimburse its program from nonfederal funds for the
improper use of program funds, provide support or reimburse its program from
nonfederal funds for the unsupported housing assistance and utility allowance
payments and related administrative fees, and implement adequate procedures and
controls to address the findings cited in this audit report. These procedures and
controls should help ensure that nearly $2 million in program funds are spent on
payments that meet HUD’s requirements.
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 issued because of the audit.
Auditee’s Response
We provided our file review results and supporting schedules to the director of
HUD’s Cleveland Office of Public Housing and the Authority’s executive director
during the audit. We also provided our discussion draft audit report to the
Authority’s executive director, its board chairman, and HUD’s staff. We held an
exit conference with the Authority’s executive director on September 18, 2006.
We asked the Authority’s executive director to provide comments on our
discussion draft audit report by September 25, 2006. The Authority’s executive
director provided written comments dated September 25, 2006, and disagreed
with our findings and recommendations. The complete text of the auditee’s
response, along with our evaluation of that response, can be found in appendix B
of this report.
2
TABLE OF CONTENTS
Background and Objective 4
Results of Audit
Finding 1: Housing Quality Standards Inspections Were Poor 5
Finding 2: Controls over Housing Assistance Payments Were Inadequate 11
Scope and Methodology 15
Internal Controls 17
Appendixes
A. Schedule of Questioned Costs and Funds to Be Put to Better Use 19
B. Auditee Comments and OIG’s Evaluation 20
C. Criteria 29
D. Unsupported Assistance Payments Due to Missing File Documentation 32
E. Housing Assistance Calculation Errors 34
3
BACKGROUND AND OBJECTIVE
The Lucas Metropolitan Housing Authority (Authority) was established under Section 3735.27
of the Ohio Revised Code to provide decent, safe, and sanitary housing. The Authority’s
jurisdiction encompasses Lucas, Wood, and Fulton Counties in Ohio. A five-member board of
commissioners governs the Authority. The Lucas County Common Pleas Court, Lucas County
Probate Court, and Lucas County Board of County Commissioners appoint one member each to
the Authority’s board for five-year staggered terms. The mayor of the City of Toledo appoints
two members to the board. The executive director is appointed by the board of commissioners
and is responsible for coordinating established policy and carrying out the Authority’s day-to-
day operations.
The Authority administers a Section 8 Housing Choice Voucher program (program) funded by
the U.S. Department of Housing and Urban Development (HUD). The Authority provides
assistance to low and moderate-income individuals seeking decent, safe, and sanitary housing by
subsidizing rents with owners of existing private housing. As of August 1, 2006, the Authority
had 3,231 units under contract with annual housing assistance and utility allowance payments
totaling more than $17 million in program funds.
Our objective was to determine whether the Authority managed its program in accordance with
HUD’s requirements.
4
RESULTS OF AUDIT
Finding 1: Housing Quality Standards Inspections Were Poor
The Authority did not adequately enforce HUD’s housing quality standards. Our inspections
found that 49 of the 62 program units statistically selected for inspection did not meet minimum
housing quality standards. The violations existed because the Authority failed to exercise proper
supervision and oversight of its program unit inspections. The Authority also lacked adequate
procedures and controls to ensure that its program units met HUD’s housing quality standards.
As a result, $59,955 in program funds was not used efficiently and effectively, and program
households lived in units that were not decent, safe, and sanitary. Based on our statistical
sample, we estimate that over the next year the Authority will pay more than $1.3 million in
housing assistance payments on units with material housing quality standards violations.
HUD’s Housing Quality
Standards Not Met
From the 738 program units that were inspected by the Authority between January
1 and March 31, 2006, we statistically selected 62 units for inspection by using
ACL Services Limited software. The 62 units were inspected to determine
whether the Authority ensured that its program units met HUD’s housing quality
standards. Our appraiser inspected the 62 units between May 15 and May 26,
2006.
Of the 62 units inspected, 49 (79 percent) had 366 housing quality standards
violations. In addition, 45 of the 49 units had 212 violations that existed before
the Authority’s previous inspections, and 35 units were considered to be in
material noncompliance since they had multiple violations and/or a violation was
noted in the Authority’s previous inspections but not corrected. Fourteen units
had 22 violations that were identified by the Authority during its previous
inspections and shown on the Authority’s inspection reports. The following table
categorizes the 366 housing quality standards violations in the 49 units.
5
Number of
Category of violations violations
Electrical 96
Window 48
Stairs, railings, and porches 34
Lead-based paint 33
Exterior surfaces 25
Smoke detectors 21
Walls 20
Floors 14
Ceilings 10
Stoves 10
Security 9
Sinks 7
Foundation 5
Ventilation 5
Flush toilet in enclosed space, fixed
wash basin, or lavatory in unit 4
Evidence of infestation 4
Refrigerators 3
Space for preparing, storing, and
serving of food 2
Roofs and gutters 2
Plumbing 2
Garbage and debris 2
Inadequate unit access 2
Chimneys 2
Other hazardous conditions 2
Tubs and showers 1
Ventilation and cooling 1
Water heaters 1
Sewers 1
Total 366
We provided our inspection results to the director of HUD’s Cleveland Office of
Public Housing and the Authority’s executive director on July 19, 2006.
Electrical Violations
Ninety-six electrical violations were present in 37 of the Authority’s program
units inspected. The following items are examples of electrical violations listed in
the table: outlets with open grounds, openings in/on junction boxes, ground fault
circuit interrupters that do not trip, and loose or exposed wires. The following
pictures are examples of the electrical-related violations identified in the
Authority’s program units inspected.
6
Unit #10000070:
Outdoor lamp
hanging from wires
at the rear entrance.
Unit #10000073:
Electrical panel
missing the
knockout plug,
exposing wires.
Window Violations
Forty-eight window violations were present in 25 of the Authority’s program
units inspected. The following items are examples of window violations listed in
the table: window does not lock, peeling paint, loose glazing, cracked panes, and
rotting windows. The following pictures are examples of the window violations
identified in the Authority’s program units inspected.
7
Unit #10000080:
Cracked glass pane on
kitchen window.
Unit #10000093:
Right rear bedroom
window does not align
to lock.
Stair, Railing, and Porch
Violations
Thirty-four stair, railing, or porch violations were present in 22 of the Authority’s
program units inspected. The following items are examples of stair, railing, or
porch violations listed in the table: rotten or damaged stairs; railings loose, short,
or missing; and deteriorated porches. The following pictures are examples of the
stair, railing, or porch violations identified in the Authority’s program units
inspected.
8
Unit #10000072:
Basement stairway
had no handrail.
Unit #10000102:
Loose front porch
boards pose a tripping
hazard.
Cause for Violations
The housing quality standards violations existed because the Authority failed to
exercise proper supervision and oversight of its program unit inspections. The
Authority also lacked adequate procedures and controls to ensure that its program
units met HUD’s housing quality standards. The Authority did not perform
quality control reinspections until June 2005, and this hindered management’s
ability to determine whether inspections were being done properly and in
accordance with the Authority’s and HUD’s requirements as discussed in 24 CFR
9
[Code of Federal Regulations] 982.401 and HUD’s Housing Choice Voucher
Program Guidebook 7420.10, dated April 2001.
Conclusion
The Authority’s households were subjected to health and safety-related violations
and the Authority did not properly use its program funds when it failed to ensure
that units complied with HUD’s housing quality standards. In accordance with 24
CFR [Code of Federal Regulations] 982.152(d), HUD is permitted to reduce or
offset any program administrative fees paid to a public housing authority if it fails
to enforce HUD’s housing quality standards. The Authority disbursed $54,127 in
program housing assistance payments for the 35 units that materially failed to
meet HUD’s housing quality standards and received $5,828 in program
administrative fees.
If the Authority implements adequate procedures and controls over its unit
inspections to ensure compliance with HUD’s housing quality standards, we
estimate that more than $1.3 million in future housing assistance payments will be
spent for units that are decent, safe, and sanitary. We determined this amount by
multiplying 295 units (estimate that would be in material noncompliance with
housing quality standards if appropriate actions are not taken by the Authority) times
$375 (average monthly subsidy of each housing unit). This amount was then
annualized to give the total estimate.
Recommendations
We recommend that the director of HUD’s Cleveland Office of Public Housing
require the Authority to
1A. Certify, along with the owners of the 35 program units cited in this finding,
that the applicable housing quality standards violations have been repaired.
1B. Reimburse its program $59,955 from nonfederal funds ($54,127 for
housing assistance payments and $5,828 in associated administrative fees)
for the 35 units that materially failed to meet HUD’s housing quality
standards.
1C. Implement procedures and controls to ensure that all units meet HUD’s
housing quality standards to prevent $1,327,500 in program funds from
being spent on units that are in noncompliance with the standards over the
next year.
1D. Routinely perform quality control inspections in accordance with
established procedures and document feedback provided to inspectors to
correct recurring inspection deficiencies noted.
10
Finding 2: Controls over Housing Assistance Payments Were
Inadequate
The Authority failed to comply with HUD’s regulations and its program administrative plan
regarding housing assistance payments. The Authority lacked documentation to support issuing
housing assistance payments to program landlords and incorrectly calculated housing assistance
payments because it did not have adequate procedures and controls to ensure that HUD’s
regulations and the Authority’s administrative plan were appropriately followed. As a result, the
Authority was unable to support $108,913 in housing assistance payments made, overpaid
$21,469 in housing assistance payments, and underpaid $1,292 in housing assistance payments.
The Authority Lacked
Documentation to Support
More Than $86,000 in Housing
Assistance Payments
The Authority lacked documentation to support housing assistance payments
totaling $86,703 for the period April 2004 through March 2006 ($84,020 in
housing assistance and $2,683 in utility allowance payments). Of the 67
household files statistically selected for review, 37 (55 percent) had the following
missing or incomplete documents:
Missing file document Number Percentage Unsupported
(11 files were missing multiple items) of files of sample payment
Missing evidence of background check done before
admission 21 31 $0
Missing birth certificate 9 13 0
Missing Section 214 declaration of citizenship 6 9 14,379
Missing rent reasonableness study 5 7 12,797
Missing current housing assistance payment
contract 4 6 29,196
Missing current lease agreement 4 6 28,014
Missing HUD-50058, Family Report and
supporting documents 2 3 2,317
Totals * 37 $86,703
* Thirty seven files were missing documents but 11
files were missing more than one document as
identified above.
The 37 files did not include documentation required by HUD’s regulations and
were not consistent with the Authority’s program administrative plan. Results of
our household file reviews are shown at appendix D.
The Authority’s files were missing documentation because its program staff did
not consistently maintain all required household documentation and supervisory
11
staff did not adequately review files to ensure that they contained the required
documentation.
The Authority Incorrectly
Calculated Housing Assistance
Payments
The Authority incorrectly calculated housing assistance payments for 39 of 67
household files reviewed, resulting in overpayments of $21,469, underpayments
of $1,292, and unsupported payments of $22,210. To determine whether the
Authority correctly calculated housing assistance payments, we reviewed income
examinations conducted from April 2004 through March 2006 for 67 program
household files statistically selected for review. Although the housing assistance
payments were incorrect for 39 files, the Authority made errors in performing
income examinations for 62 of the 67 files reviewed. The 62 files contained the
following types of errors, with several files containing more than one error:
¾ 47 had annual income calculation errors for one or more years,
¾ 38 had incorrectly used third-party verifications,
¾ 37 had missing or unsent third-party verifications,
¾ 24 used incorrect utility allowances,
¾ 13 had incorrectly classified food stamps,
¾ 11 had unverified income figures identified by HUD’s Enterprise
Income Verification system,
¾ 10 used incorrect payment standards,
¾ Eight used the incorrect unit type,
¾ Six had incorrectly classified Social Security or Supplemental Security
Income,
¾ Four used incomplete rent reasonableness studies,
¾ Four used an incorrect contract rent,
¾ Three used an incorrect voucher size,
¾ Two used undocumented utility types, and
¾ Two did not charge established minimum rents.
The annual income calculation errors were attributed to staff (a) not including
bonuses, overtime, or pay increases or following the Authority’s policies for
annualizing incremental wages and child support; (b) erroneously including or
excluding a family member’s allowable income deductions; (c) erroneously
including Medicare premium deductions; and (d) failing to make retroactive
adjustments for unreported income. The errors occurred because the Authority’s
staff did not follow established procedures for completing income examinations
through the use of standardized income examination and file management
procedures. The Authority’s program landlord manager also did not adequately
document the consideration of utilities and other amenities for determining gross
rent for rent reasonableness studies as required by HUD’s regulations and the
Authority’s administrative plan. In addition, management performing quality
control reviews did not adequately identify file deficiencies or require corrective
12
actions when deficiencies were identified—resulting in continued overpayments
and underpayments of housing assistance. The Authority’s administrative plan
also did not address how households would be reimbursed when an underpayment
of housing assistance payment occurs.
Appendix E of this report details the housing assistance payment errors that
resulted from the Authority’s incorrect calculations.
HUD performed a rental integrity monitoring review in 2003 and a rental integrity
monitoring re-review in 2004. Both HUD reviews identified income calculation
errors and third-party verification issues that we found during our file reviews.
HUD made a recommendation for the Authority to adopt new policies based on
HUD guidance to improve errors caused by third-party verifications. The
Authority, however, had not adopted these policies and continued to have
problems with income calculations and verifications.
Conclusion
The Authority did not properly use its program funds when it failed to comply
with HUD’s regulations and its own administrative plan. As a result of these
weaknesses, the Authority is at risk of overpaying an estimated $627,646
($667,834 in overpayments and $40,188 in underpayments) in program housing
assistance payments over the next 12 months if the conditions cited in this finding
are not corrected. Our calculation of this estimate is described in the Scope and
Methodology section of this audit report.
As previously mentioned the Authority disbursed $108,913 ($86,703 plus
$22,210) in housing assistance payments without proper documentation, overpaid
$21,469 in housing assistance payments, and underpaid $1,292 in housing
assistance payments. In addition, the Authority received $20,700 in program
administrative fees related to the unsupported, overpaid, and underpaid housing
assistance payments.
Recommendations
We recommend that the director of HUD’s Cleveland Office of Public Housing
require the Authority to
2A. Provide supporting documentation or reimburse its program $86,703 from
nonfederal funds ($84,020 in housing assistance and $2,683 in utility
allowances payments) for the unsupported payments related to the 37
household files cited in this finding.
2B. Implement adequate procedures and controls to ensure that all required
documentation is maintained in its current household files to support
eligibility for housing assistance and utility allowance payments.
13
2C. Provide documentation or reimburse its program from nonfederal funds
for the $22,210 in unsupported assistance due to the Authority’s income
calculation errors during the examination process.
2D. Reimburse its program $21,469 from nonfederal funds for the
overpayment of housing assistance payments cited in this finding.
2E. Reimburse the appropriate households $1,292 for the underpayment of
housing assistance payments.
2F. Reimburse its program $20,700 from nonfederal funds for the
administrative fees associated with the 39 household files with payment
calculation errors cited in this finding.
2G. Implement adequate procedures and controls to ensure that its staff
properly compute housing assistance payments and obtain required third-
party verifications to prevent $627,646 in program funds from being
overspent within the next 12 months due to income calculation errors.
2H. Revise its program administrative plan to address how households will be
reimbursed when an underpayment of housing assistance occurs.
14
SCOPE AND METHODOLOGY
To accomplish our objective, we reviewed:
• HUD’s program requirements at 24 CFR [Code of Federal Regulations] Parts
5 and 982; HUD’s Public and Indian Housing Notices 2004-1 and 2005-9;
HUD document, entitled “Guidelines for Projecting Annual Income When
Upfront Income Verification Data Is Available”; HUD’s Housing Choice
Voucher Program Guidebook 7420.10; and the Authority’s program
administrative plan, effective May 2003, and revised edition, effective
September 2005.
• The Authority’s program accounting records, household files, computerized
database, written policies and procedures, board meeting minutes for 2004 and
2005, organizational chart, and program annual contributions contract.
• HUD’s files for the Authority.
We also interviewed the Authority’s employees, HUD staff, and program households.
Using ACL Services Limited software, we statistically selected 62 of the Authority’s program
units to inspect from 738 units that were inspected and passed by the Authority from January 1
through March 31, 2006. The 62 units were selected to determine whether the Authority ensured
that its program units met HUD’s housing quality standards. Our attribute sampling criteria used
a 90 percent confidence level, 50 percent estimated error rate, and a precision of plus or minus
10 percent.
Our sampling results determined that 35 of 62 units (56 percent) materially failed to meet HUD’s
housing quality standards. This was above our 50 percent estimated error rate but within our
precision range of plus or minus 10 percent. To be conservative, we used 40 percent (lower
limit) as our expected error rate to estimate potential future savings (funds to be put to better
use). Materially failed units were those units in which more than one of the identified violations
existed but was not cited the last time the Authority conducted its inspections, or at least one
violation was previously cited by the Authority but not corrected.
The Authority’s January through March 2006 quarterly voucher management system data
summary showed that the average monthly housing assistance payment was $375. Using the
lower limit of the estimate of the number of units and the average housing assistance payment,
we estimated that the Authority will annually spend $1,327,500 (295 units times $375 average
assistance payment times 12 months) for units that are in material noncompliance with HUD’s
housing quality standards. This estimate is presented solely to demonstrate the annual amount of
program funds that could be put to better use on decent, safe, and sanitary housing if the
Authority implements our recommendations. While these benefits would recur indefinitely, we
were conservative in our approach and only included the initial year in our estimate.
15
Using our lower precision limit of 40 percent (based on a 50 percent error rate and a 10 percent
precision), we applied this error rate to the population of 738 units inspected and passed by the
Authority over a three-month period. We estimate that the Authority will spend more than $1.3
million in housing assistance payments for 295 units that materially fail to meet housing quality
standards (computed as 295 units times the average annual housing assistance payment of
$4,500) if appropriate actions are not taken to correct housing quality standards violations.
We also statistically selected 67 of the Authority’s program household files using Excel and EZ
Quant Dollar Unit Variable Statistical Sampling System software from the 3,383 current
households enrolled in the Authority’s program as of February 1, 2006. The 67 household files
were selected to see whether the Authority determined household income and eligibility and
issued housing assistance payments in accordance with HUD’s regulations and its own
administrative plan. Our sampling criteria used a 90 percent confidence level, 50 percent
estimated error rate, and 10 percent precision rate.
To determine our estimate of $627,646 in future overpayments due to calculation errors in
household reexaminations during the next 12 months, we reviewed the accuracy of housing
assistance payments made to our statistical sample of the 67 households. We applied an error
rate of 4.37 percent in overpayments to the average annual housing assistance payments
disbursed for the 3,383 households ($15,280,488) and subtracted an error rate of .26 percent in
underpayments to the same housing assistance disbursement of $15,280,488. The error rates
were determined by dividing the overpayments ($21,469) and the underpayments ($1,292) by the
total housing assistance paid for the 67 households for the period of our review ($491,222). We
calculated the Authority’s average annual housing assistance expense by annualizing the total
payments made to all program households in our sample’s population as of February 1, 2006
($1,273,374 times 12).
We determined the administrative fees applicable to household files with subsidy calculation
errors by applying the average monthly administrative fee received per unit to the number of
months that the Authority miscalculated the subsidy for each household.
We performed our on-site audit work between January and June 2006 at the Authority’s program
office, located at 211 South Byrne Road, Toledo, Ohio. The audit covered the period from July
1, 2004, through December 31, 2005, but was expanded when necessary. We were able to rely
on the Authority’s automated data on housing assistance payments, household data, and unit
inspections through comparisons with hard copy documentation such as household files.
We performed our audit in accordance with generally accepted government auditing standards.
16
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,
• Compliance with applicable laws and regulations, and
• Safeguarding resources.
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 objective:
• Program operations – Policies and procedures that management has
implemented to reasonably ensure that a program meets its objectives.
• 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.
• 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.
We assessed the relevant controls identified above.
A significant weakness exists if internal controls do not provide reasonable
assurance that the process for planning, organizing, directing, and controlling
program operations will meet the organization’s objectives.
17
Significant Weakness
Based on our review, we believe the following item is a significant weakness:
• The Authority failed to exercise proper supervision and oversight of unit
inspections, household files, and housing assistance payments (see findings 1
and 2).
18
APPENDIXES
Appendix A
SCHEDULE OF QUESTIONED COSTS
AND FUNDS TO BE PUT TO BETTER USE
Recommendation Funds to be put
number Ineligible 1/ Unsupported 2/ to better use 3/
1B $59,955
1C $1,327,500
2A $86,703
2C 22,210
2D 21,469
2E 1,292
2F 20,700
2G 627,646
Totals $102,124 $108,913 $1,956,438
1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
that the auditor believes are not allowable by law; contract; or federal, state, or local
policies or regulations.
2/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
or activity when we cannot determine eligibility at the time of the 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/ Recommendations that funds be put to better use are estimates of amounts that could be
used more efficiently if an OIG recommendation is implemented. This includes
reductions in outlays, deobligation of funds, withdrawal of interest subsidy costs not
incurred by implementing recommended improvements, avoidance of unnecessary
expenditures noted in preaward reviews, and any other savings that are specifically
identified. In this instance, if the Authority implements our recommendations, it will
cease to incur program costs for units that are not decent, safe, and sanitary and instead,
will expend the proper amount of funds for units that meet HUD’s standards. Once the
Authority successfully improves its controls, this will be a recurring benefit. Our
estimate reflects only the initial year of these recurring benefits. Additionally, we have
addressed weaknesses in the calculation of housing assistance payments that should result
in further recurring benefits for the Authority. We included only the first year benefit
from added controls in this area.
19
Appendix B
AUDITEE COMMENTS AND OIG’s EVALUATION
Ref to OIG Evaluation Auditee Comments
Comment 1
20
Ref to OIG Evaluation Auditee Comments
Comment 2
Comment 3
Comment 4
Comment 5
21
Ref to OIG Evaluation Auditee Comments
Comment 6
Comment 7
22
Ref to OIG Evaluation Auditee Comments
Comment 8
Comment 9
Comment 10
Comment 11
Comment 12
Comment 13
23
Ref to OIG Evaluation Auditee Comments
Comment 14
Comment 15
Comment 16
Comment 17
Comment 18
24
Ref to OIG Evaluation Auditee Comments
Comment 19
Comment 20
Comment 21
25
OIG Evaluation of Auditee Comments
Comment 1 We statistically selected 62 units for inspection from the 738 program units that
were inspected by the Authority between January 1 and March 31, 2006. Our
appraiser inspected the units between May 15 and May 26, 2006. Our statistical
sample was done to avoid selecting units that might have materially changed since
the Authority’s last inspections by focusing on units that the Authority passed
within the last four months.
Comment 2 We agree that the Authority does have some housing stock that was built before
ground fault circuit interrupters were available. However, we disagree with the
Authority’s contention that a ground fault circuit interrupter will not operate
properly in an older home having a two wire electrical system. A ground fault
circuit interrupter can be installed to function as designed in these homes. When
our appraiser inspected the units and tested the outlets with an electrical circuit
tester, these safety devices either failed to trip or tripped but did not cut off the
flow of electricity as designed.
Comment 3 Our appraiser inspected the Authority’s Section 8 units in accordance with HUD’s
housing quality standards. As evidenced by the photographs provided to the
Authority, the violations we cited as defects were window cracks that allowed for
water infiltration and also posed a potential cutting hazard. The outlet covers we
cited were large cracks or holes that exposed the wiring underneath. We took a
strict interpretation on missing light globes—such as exposed wiring or lights
hanging loose from the fixtures. The Authority stated that we cited five violations
for tenant clutter. We actually cited two such violations and these were not
included as a preexisting condition.
Comment 4 The amounts that we questioned represented monthly housing assistance
payments made to the owners as well as the administrative fees paid to the
Authority for the period of time the unit should have been abated—up until the
end of May 2006. As previously stated in Comment 2, when our appraiser
inspected the units and tested the electrical outlets with a circuit tester, these
safety devices either failed to trip or tripped but did not cut off the flow of
electricity as designed.
Comment 5 The inspections conducted by our appraiser within four months of the Authority’s
inspections disclosed that 79 percent failed HUD’s housing quality standards.
Fifty six percent failed materially, due to more than one violation existing
undetected during the Authority’s inspections, or where at least one violation was
cited by the Authority’s inspectors but was later passed even though the condition
was not corrected. The annual training for inspection staff is important and
should be continued. The Authority also began conducting quality control
reinspections in June 2005, but the Authority still needs to implement adequate
procedures and controls to provide reasonable assurance that the assisted units are
in compliance with HUD’s housing quality standards.
26
Comment 6 We did not cite any problems with the Authority’s abatement process. However,
as noted in previous comments, the Authority’s inspection process needs
improvement since the Authority’s inspectors were not identifying all of the
housing quality standards violations that existed.
Comment 7 The Authority contends that a clerical specialist kept a spreadsheet to track
criminal history checks. During the audit, we contacted the specialist for the
program and she informed us that she maintained the spreadsheet from March
2003 through March 2005, when she was in that position. The specialist could
not locate the spreadsheet during our audit. Another specialist at the Authority
maintained a log of criminal background checks for its public housing program,
but not for program households. The Authority is required to maintain complete
and accurate accounts and other records for the program during the term of each
assisted lease and for at least three years thereafter in accordance with HUD’s
regulations at 24 CFR [Code of Federal Regulations] 982.158(a).
Comment 8 The nine files we cited for missing birth certificates were missing the birth
certificates when we reviewed the files, and we did not question program costs for
this issue.
Comment 9 We agree that third party documentation is better than a certification. However,
HUD’s regulations at 24 CFR [Code of Federal Regulation] 5.508 specifically
require a signed declaration of U.S. citizenship or U.S. nationality in order to be
eligible for assistance.
Comment 10 The Authority did not provide this documentation during our audit or with its
comments to our report. The Authority should provide the documentation to
HUD for review.
Comment 11 As previously stated, the Authority is required to maintain complete and accurate
accounts and other records for the program during the term of each assisted lease
and for at least three years thereafter in accordance with HUD’s regulations at 24
CFR [Code of Federal Regulations] 982.158(a). The Authority did not provide
this documentation during our audit or with its comments to our report. The
Authority should provide the documentation to HUD for review.
Comment 12 A copy of the most recent lease should be retained despite the household’s time of
occupancy. The Authority did not provide this documentation during our audit or
with its comments to our report. The Authority should provide the documentation
to HUD for review.
Comment 13 For the five files that were missing rent reasonableness studies, the Authority
concluded that one should be ignored due to the household’s length of occupancy
and the other four should be dropped since they found rent reasonableness studies
for other clients in the same complex. There should be a rent reasonableness
study in every household’s file demonstrating that the rent for that unit was
determined to be reasonable. In addition, we determined that the Authority had
not been considering utilities and amenities provided in its determinations of rent
27
reasonableness, so comparisons with other units in the same complex would not
fully support rent reasonableness. The Authority should provide the
documentation to HUD for review.
Comment 14 We agree the Authority should provide staff with followup training. However, as
evidenced by our audit results, the Authority’s staff either forgot to obtain or file
certain documents, or documents were removed when the filing system was
overhauled. Adequate procedures and controls to ensure all required
documentation is maintained in its current household files to support eligibility
for housing assistance and utility allowance payments must still be implemented.
Comment 15 The Authority did not provide any documentation to support a reduction in the
amount of unsupported assistance we calculated due to its income calculation
errors during the examination process.
Comment 16 The Authority did not provide any documentation during our audit or with its
comments to our report to warrant a reduction in the dollar amount of this finding.
The Authority should provide the documentation to HUD for review.
Comment 17 As previously stated, the Authority did not provide any documentation during our
audit or with its comments to our report to warrant a reduction in the dollar
amount of this finding. The Authority should provide the documentation to HUD
for review.
Comment 18 The recommendation is that the administrative fees be repaid from nonfederal
funds in accordance with HUD’s regulations at 24 CFR [Code of Federal
Regulations] 982.152(d).
Comment 19 Funds be put to better use are estimates of amounts that could be used more
efficiently if an OIG recommendation is implemented. This includes reductions
in outlays, deobligation of funds, withdrawal of interest subsidy costs not incurred
by implementing recommended improvements, avoidance of unnecessary
expenditures noted in preaward reviews, and any other savings that are
specifically identified. Our Office is statutorily required by Section 5 of the
Inspector General Act to report funds to be put to better use that are identified
during our audits. Given our analysis and the statutory requirement, we believe
that our calculation of funds to be put to better use is sound.
Comment 20 When the Authority’s administrative plan revisions are completed, a copy of the
plan should be provided to HUD for review.
Comment 21 We agree with the Authority that an increased workload may increase the risk of
errors and further emphasizes the importance of having adequate procedures and
controls that staff have been trained to follow.
28
Appendix C
CRITERIA
Finding 1
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.152(d) states that HUD may
reduce or offset any administrative fee to a public housing authority, in the amount determined
by HUD, if the authority fails to perform its administrative responsibilities correctly or
adequately under the program, such as not enforcing HUD’s housing quality standards.
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.305(a) state that the public
housing authority may not give approval for the family of the assisted tenancy or execute a
housing assistance contract until the authority has determined that all of the following meet
program requirements: (1) the unit is eligible, and (2) the unit has been inspected by the authority
and passes HUD’s housing quality standards.
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.401 require that all program
housing meet HUD’s housing quality standards performance requirements, both at
commencement of assisted occupancy and throughout the tenancy.
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.404 require owners of program
units to maintain the units in accordance with HUD’s housing quality standards. If the owner
fails to maintain the dwelling unit in accordance with the standards, the authority must take
prompt and vigorous action to enforce the owner’s obligations. The authority’s remedies for
such breach of the housing quality standards include termination, suspension, or reduction of
housing assistance payments and termination of the housing assistance payment contract. The
authority must not make any housing assistance payments for a dwelling unit that fails to meet
housing quality standards unless the owner corrects the defect within the period specified by the
authority and the authority verifies the correction. If a defect is life threatening, the owner must
correct the defect within 24 hours. For other defects, the owner must correct them within 30
calendar days.
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.405(a) require public housing
authorities to perform unit inspections before the initial move-in and at least annually. The
authority must inspect the unit leased to a family before the term of the lease, at least annually
during assisted occupancy, and at other times as needed to determine whether the unit meets
housing quality standards.
Finding 2
HUD’s regulations at 24 CFR [Code of Federal Regulations] 5.901(a) include requirements that
apply to criminal conviction background checks by public housing authorities that administer
Section 8 and public housing programs when they obtain criminal conviction records, under the
authority of section 6(q) of the 1937 Act [United States Code 42.1437d(q)], from a law
enforcement agency to prevent admission of criminals to public housing and Section 8 housing
and to assist in lease enforcement and eviction.
29
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.158(a) state that the public
housing authority must maintain complete and accurate accounts and other records for the
program in accordance with HUD requirements in a manner that permits a speedy and effective
audit. During the term of each assisted lease and for at least three years thereafter, the authority
must keep (1) a copy of the executed lease, (2) the housing assistance payment contract, and (3)
the application from the family. The authority must keep the following records for at least three
years: records that provide income, racial, ethnic, gender, and disability status data on program
applicants and participants; unit inspection reports; lead-based paint records as required by part
35, subpart B of this title; records to document the basis for an authority’s determination that rent
to owner is a reasonable rent (initially and during the term of a contract); and other records
specified by HUD.
HUD’s regulations at 24 CFR [Code of Federal Regulations] 5.508 (a through c), state that
eligibility for assistance or continued assistance is contingent on submission of documentary
evidence of citizenship or eligible immigration status. U.S. citizens and U.S. nationals are
required to provide a signed declaration of U.S. citizenship or U.S. nationality. Eligible non-
citizens must provide a signed declaration of immigration status. Each adult in the household
must sign a certification for himself/herself and an adult in the family must sign a certification
for each child in the family. Subpart 5.520(c)(2) outlines how prorated assistance is calculated
for family members who fail to submit evidence of citizenship or to establish eligible
immigration status.
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.516(a)(1) require the authority
to conduct a reexamination of family income and composition at least annually. The authority
must obtain and document in the household file third-party verification or why third party
verification was not available for the following factors: (i) reported family annual income, (ii)
the value of assets, (iii) expenses related to deductions from annual income, and (iv) other factors
that affect the determination of adjusted income. At any time, the authority may conduct an
interim reexamination of family income and composition. Interim examinations must be
conducted in accordance with policies in the authority’s administrative plan. Subpart (f) requires
the housing authority to establish procedures to assure that income provided by the household is
complete and accurate.
HUD’s guidance, entitled “HUD Guidelines for Projecting Annual Income When Upfront
Income Verification Data Is Available,” states that its guidelines are provided to assist housing
authorities in consistently and uniformly resolving income discrepancies. When upfront income
verification data are substantially different from household-provided income information,
housing authorities shall follow these guidelines: (1) the housing authority shall request written
third-party verification from the discrepant income source, in accordance with 24 CFR
5.236(3)(i); (2) the housing authority should review historical income data for patterns of
employment, paid benefits, or receipt of other income when the housing authority cannot readily
anticipate income, such as in cases of seasonal employment, unstable working hours, and
suspected fraud; (3) the housing authority must analyze all data, third-party verifications, and
other documents provided by the family and attempt to resolve the income discrepancy; and (4)
the housing authority will use the most current verified income data (and historical income data
if appropriate) to calculate anticipated annual income.
30
HUD Housing Choice Voucher Program Guidebook 7420.10, chapter 5, states that generally the
housing authority should use current circumstances to anticipate annual income unless
verification forms indicate an imminent change. Housing authorities may choose among several
methods to determine the anticipated annual income. The following are two acceptable methods
of calculating annual income: calculating projected annual income by annualizing current
income (and conducting an interim reexamination if income changes) or using information
available to average anticipated income from all known sources when the sources are expected to
change during the year. Lucas Metropolitan Housing Authority’s Section 8 administrative plan
does not describe procedures for calculating household income at annual or interim
reexaminations. The Authority’s policies and procedures manual describe specific procedures
for annualizing income.
HUD’s regulations at 24 CFR [Code of Federal Regulations] 982.507(a through b) state that the
housing authority may not approve a lease until the authority determines that the initial rent to
owner is a reasonable rent. The housing authority must determine whether the rent to owner is a
reasonable rent in comparison with rent for other comparable unassisted units. To make this
determination, the authority must consider the location, quality, size, unit type, and age of the
contract unit and any amenities, housing services, maintenance, and utilities to be provided by
the owner in accordance with the lease.
The Authority’s program administrative plan, chapter VII, part D, states that when a voucher
holder requests approval for a new unit, the gross rent for the requested unit is compared with
gross rents for at least two units of the same size in the same census tract or in the closest census
tracts for which current rental information is available. To the greatest extent possible, units
used for comparison will be units that are similar to the subject unit in location, quality, size, unit
type, age, and condition and in utilities, maintenance, housing services, and amenities provided
by the owner. If the units used for comparison differ from the subject unit in any of these
respects, upward or downward adjustments may be made to the rent approved. A certification of
rent reasonableness, showing the method used to determine that the approved rent is reasonable,
will be kept in the participant’s file.
31
Appendix D
UNSUPPORTED ASSISTANCE PAYMENTS DUE TO
MISSING FILE DOCUMENTATION
Evidence of Current Total
OIG created criminal HUD-50058, housing unsupported
household background Signed section Family Report, assistance Current Rent housing
identification check before Birth 214 declaration and supporting payment lease reasonableness assistance
number admission* certificate* of citizenship verifications contract agreement study payments paid
10000001 $0
10000002 XXXXX 0
10000003 X 0
10000004 X 0
10000005 0
10000006 0
10000007 0
10000008 0
10000009 X X X 6,372
10000010 0
10000011 XX 1,412
10000012 X 0
10000013 X 2,119
10000014 0
10000015 0
10000016 0
10000017 0
10000018 0
10000019 0
10000020 0
10000021 X 2,317
10000022 X 0
10000023 X 13,217
10000024 0
10000025 XX 0
10000026 0
10000027 0
10000028 0
10000029 0
10000030 X X 5,191
10000031 X 0
10000032 X X 0
10000033 X X** X** 0
10000034 X 0
10000035 XX 0
10000036 X X 8,613
10000037 X 10,693
10000038 X X X 10,185
32
Appendix D
UNSUPPORTED ASSISTANCE PAYMENTS DUE TO
MISSING FILE DOCUMENTATION (CONTINUED)
Evidence of
criminal Signed Current Total
OIG created background Section 214 HUD-50058, housing unsupported
household check declaration Family Report, assistance Current Rent housing
identification before Birth of and supporting payment lease reasonableness assistance
number admission* certificate* citizenship verifications contract agreement study payments paid
10000039 X $0
10000040 X 1,628
10000041 0
10000042 0
10000043 XXX 0
10000044 0
10000045 X 2,881
10000046 0
10000047 X XX 1,148
10000048 0
10000049 XXX 0
10000050 0
10000051 0
10000052 X 7,136
10000053 0
10000054 X 0
10000055 X 0
10000056 X X 9,607
10000057 X X 0
10000058 X 1,636
10000059 X 0
10000060 0
10000061 X X 2,548
10000062 X 0
10000063 X 0
10000064 0
10000065 0
10000066 0
10000067 X XX 0
Totals 21 9 6 2 4 4 5 $86,703
Note: * = Indicates document that although missing, is not required by HUD’s regulations,
so we did not question the related housing assistance payment.
X = For documents required for each family member; more than one X means the
document was missing for multiple family members.
X** = We did not question the housing assistance payment since the household had lived
in the same unit under the existing contract for more than 20 years.
33
Appendix E
HOUSING ASSISTANCE CALCULATION ERRORS
Apr. 1, 2004, to Mar. 31, 2005 Apr. 1, 2005, to Mar, 31, 2006 Total audit scope
OIG created housing assistance payment errors housing assistance payment errors housing assistance payment errors
household Ineligible
identification Ineligible over Ineligible
number over (under) Unsupported Total (under) Unsupported Total over (under) Unsupported Total
10000001 $448 $448 $0 $0 $448 $0 $448
10000002 0 0 (30) (30) (30) 0 (30)
10000003 130 130 2,507 2,507 2,637 0 2,637
10000004 0 0 0 0 0 0
10000005 276 276 54 54 330 0 330
10000006 0 0 0 $437 437 0 437 437
10000007 0 0 0 0 0 0 0
10000008 204 204 96 96 300 0 300
10000009 84 84 228 228 312 0 312
10000010 96 96 44 44 140 0 140
10000011 0 0 44 44 44 0 44
10000012 0 0 0 0 0 0 0
10000013 0 0 0 0 0 0 $0
10000014 0 0 (43) (43) (43) 0 (43)
10000015 0 0 2,844 2,844 2,844 0 2,844
10000016 0 0 74 74 74 0 74
10000017 0 0 0 0 0 0 0
10000018 0 0 0 0 0 0 0
10000019 543 543 62 62 605 0 605
10000020 0 0 0 0 0 0 0
10000021 0 0 0 0 0 0 0
10000022 0 0 0 0 0 0 0
10000023 0 $150 150 250 250 500 250 400 650
10000024 0 0 0 0 0 0 0
10000025 (57) (57) 0 0 (57) 0 (57)
10000026 0 0 0 0 0 0 0
10000027 0 0 0 0 0 0 0
10000028 (142) (142) 0 0 (142) 0 (142)
10000029 0 0 0 0 0 0 0
10000030 0 0 0 0 0 0 0
10000031 0 0 2,865 2,865 2,865 0 2,865
10000032 1,380 1,380 216 216 1,596 0 1,596
10000033 144 144 (12) (12) 132 0 132
10000034 0 0 0 0 0 0 0
10000035 0 0 (401) (401) (401) 0 (401)
10000036 0 0 0 0 0 0 0
10000037 0 0 0 0 0 0 0
10000038 340 340 19 19 359 0 359
34
Appendix E
HOUSING ASSISTANCE CALCULATION ERRORS (CONTINUED)
Apr. 1, 2004, to Mar. 31, 2005 Apr. 1, 2005, to Mar, 31, 2006 Total audit scope
OIG created housing assistance payment errors housing assistance payment errors housing assistance payment errors
household Ineligible Ineligible
identification Ineligible over over
number over (under) Unsupported Total (under) Unsupported Total (under) Unsupported Total
10000039 $0 $0 $0 $0 $0 $0 $0
10000040 780 780 0 0 780 0 780
10000041 0 $732 732 60 $366 426 60 1,098 1,158
10000042 0 0 0 0 0 0 0
10000043 48 48 186 186 234 0 234
10000044 2,652 2,544 5,196 0 1,272 1,272 2,652 3,816 6,468
10000045 197 197 595 354 949 792 354 1,146
10000046 60 60 40 40 100 0 100
10000047 300 2,700 3,000 (63) (63) 237 2,700 2,937
10000048 0 0 0 0 0 0 0
10000049 0 0 0 0 0 0 0
10000050 0 0 0 0 0 0 0
10000051 0 0 1,506 1,506 1,506 0 1,506
10000052 0 0 0 0 0 0 0
10000053 156 156 26 26 182 0 182
10000054 0 0 (33) (33) (33) 0 (33)
10000055 (333) (333) (51) (51) (384) 0 (384)
10000056 0 0 0 0 0 0 0
10000057 0 0 0 0 0 0 0
10000058 0 0 0 0 0 0 0
10000059 0 0 0 0 0 0 0
10000060 0 0 (88) (88) (88) 0 (88)
10000061 732 732 84 84 816 0 816
10000062 602 602 273 273 875 0 875
10000063 0 5,388 5,388 0 8,017 8,017 0 13,405 13,405
10000064 96 96 110 110 206 0 206
10000065 12 12 81 81 93 0 93
10000066 0 0 0 0 0 0 0
10000067 (96) (96) (18) (18) (114) 0 (114)
Totals $8,652 $11,514 $20,166 $11,525 $10,696 $22,221 $20,177 $22,210 $42,387
Subtotals:
Amount overpaid: $9,280 $12,264 $21,469
Amount underpaid: ($628) ($739) ($1,292)
35
Lucas Metropolitan Housing Authority, Toledo, Ohio, Did Not Effectively Operate Its Section 8 Housing Choice Voucher Program
Published by the Department of Housing and Urban Development, Office of Inspector General on 2006-09-29.
Below is a raw (and likely hideous) rendition of the original report. (PDF)