oversight

The Housing Authority of the Birmingham, Alabama District Did Not Ensure That Section 8 Units Were Decent, Safe, and Sanitary

Published by the Department of Housing and Urban Development, Office of Inspector General on 2006-10-25.

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

                                                                Issue Date
                                                                         October 25, 2006
                                                                Audit Report Number
                                                                         2007-AT-1001




TO:        R. Edmond Sprayberry, Director, Office of Public Housing, Birmingham,
            Alabama, 4CPH

FROM:

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


SUBJECT: The Housing Authority of the Birmingham, Alabama District Did Not Ensure
         That Section 8 Units Were Decent, Safe, and Sanitary


                                  HIGHLIGHTS

 What We Audited and Why

            As part of the U.S. Department of Housing and Urban Development (HUD),
            Office of the Inspector General’s (OIG) strategic plan, we audited the Housing
            Authority of the Birmingham District’s (Authority) Section 8 Housing Choice
            Voucher program. We selected the Authority for review based on a Section 8 risk
            assessment we conducted. Our audit objective was to determine whether the
            Authority’s Section 8 units met housing quality standards in accordance with
            HUD requirements.


 What We Found


            The Authority failed to ensure that its Section 8 housing stock met housing
            quality standards. We determined that 88 percent, or 58 of 66 units, did not meet
            housing quality standards. Of the 58 units, 38 were in material noncompliance.


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           This condition occurred because the Authority’s management did not implement
           adequate internal controls over its inspection process and did not have adequate
           procedures for conducting inspections. As a result, tenants lived in units that
           were not decent, safe, and sanitary, and the Authority made housing assistance
           payments for units that did not meet standards. We estimate that over the next
           year, the Authority will pay housing assistance payments of more than $10.4
           million for units in material noncompliance with housing quality standards if it
           does not implement adequate controls.

What We Recommend


           We recommend that the director of the Office of Public and Indian Housing require
           the Authority to inspect the 58 units that did not meet housing quality standards to
           verify that the owners took appropriate corrective action to make the units decent,
           safe, and sanitary. If appropriate actions were not taken, the Authority should abate
           the rents or terminate the housing assistance payment contracts. The director should
           also require the Authority to implement internal controls, policies, and procedures
           that ensure units meet housing quality standards and inspections meet HUD
           requirements to prevent more than $10.4 million from being spent on units that
           are in material noncompliance with standards. In addition, the director should
           require the Authority to develop and implement quality control inspection
           procedures.

           For each recommendation without a management decision, please respond and
           provide status reports in accordance with HUD Handbook 2000.06, REV-3.
           Please furnish us copies of any correspondence or directives issued because of the
           audit.

Auditee’s Response


           We discussed the findings with Authority and HUD officials during the audit. We
           provided a copy of the draft report to Authority officials on September 12, 2006,
           for their comments and discussed the report with the officials at the exit
           conference on September 18, 2006. The Authority provided its written comments
           to our draft report on September 18, 2006.

           The Authority disagreed with certain statements, but stated it has begun
           implementing the recommendations. 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 Objective                                                           4

Results of Audit
      Finding 1: The Authority’s Section 8 Units Did Not Meet Housing Quality      5
                 Standards


Scope and Methodology                                                              12

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
   C. Schedule of Units in Material Noncompliance with Housing Quality Standards   24




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                      BACKGROUND AND OBJECTIVE

The Housing Authority of the Birmingham District (Authority) was incorporated in 1935 and in
1937 began participation under the provisions of the United States Housing Act of 1937. Its
primary objective is to provide subsidized public and leased housing within the city of
Birmingham, Alabama, in compliance with its annual contributions contract with the U.S.
Department of Housing and Urban Development (HUD).

A five-member board of commissioners governs the Authority, with members appointed by the
mayor of Birmingham, Alabama. Members are appointed for staggered terms. Bob Friedman is
the board chairman, and Ralph Ruggs is the executive director.

The Authority administers about 4,000 housing choice vouchers. The annual housing assistance
payments and administrative fees approved were $22.6 million for fiscal year 2004, $23.6
million for fiscal year 2005, and $24.2 million for fiscal year 2006.

HUD’s Alabama State Office of Public Housing in Birmingham, Alabama, is responsible for
overseeing the Authority. HUD designated the Authority as a standard performing Section 8
Public Housing Authority for fiscal years 2004 and 2005.

Our audit objective was to determine whether the Authority’s Section 8 units met housing quality
standards in accordance with HUD requirements.




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                                               4
                                   RESULTS OF AUDIT

Finding 1: The Authority’s Section 8 Units Did Not Meet Housing
           Quality Standards

Our inspection of 66 units showed that 58 units (88 percent) did not meet minimum housing quality
standards. Of the 58 units not meeting standards, 38 were in material noncompliance. Projecting
the results of the statistical sample to the population indicates that at least 1,818 of the Authority’s
3,816 units would not meet standards. This condition occurred because the Authority’s
management did not implement adequate internal controls over its inspection process and did not
have adequate procedures for conducting inspections. As a result, Section 8 tenants lived in units
that were not decent, safe, and/or sanitary. The Authority made housing assistance payments for
units that did not meet housing quality standards. Based on the sample, we estimate that over the
next year, the Authority will pay housing assistance payments of more than $10.4 million for units
that are in material noncompliance with housing quality standards.



 Units Contained Numerous
 Health and Safety Violations


                The Authority’s Section 8 units contained numerous health and safety violations.
                We found 309 standards violations in 58 of the 66 units inspected. The following
                table lists the most frequently occurring violations for the 58 units.

                      Type of         Number of         Number         Percentage
                     deficiency       deficiencies      of units        of units
                     Electrical            91              45              78
                      hazards
                     Plumbing               40              25              43
                      Building              38              22              38
                      exterior
                       Doors                30              22              38

                Additionally, 38 of the 58 failed units were in material noncompliance with
                housing quality standards. Appendix C provides details on the 38 units.




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                                                   5
        The most prevalent deficiencies were electrical hazards, including ungrounded
        electrical outlets and exposed wiring.




                        An active water leak from roof in light fixture with visible
                        water damage to ceiling and fixture.




                        Light switch cover missing in the bathroom of unit
                        where children live.


        We also identified hazards such as water leaks, open sewer pipe, deteriorating
        exterior structures, unsafe stairs, and unsecured/damaged doors.




                        Pipe under sink actively leaking with visible
                        mildew stains.


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                    Broken and open sewer line on front of unit.




                    Roof collapsing on exterior storage building in
                    the backyard where children play.




                    Stairs on deck not properly secured. The piling on
                    the exterior deck was not set in concrete.




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                           Damaged door on exterior laundry room used by
                           the tenant poses a safety danger to the family and
                           unauthorized access to the home.

          In addition, we identified conditions such as broken or missing window locks and
          insect infestation problems.




                           Window lock is missing.

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

          Authority officials stated that the inspectors either overlooked the housing
          deficiencies or were not aware to identify items based on housing quality standards
          requirements, which resulted in the inspectors passing units with housing quality
          violations. Authority officials also stated that the inspections were made at a time
          when there were only four inspectors to perform the inspections. They stated that
          although an independent inspection firm provided inspection assistance to the
          Authority, the workload for the four inspectors had dramatically increased.




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The Inspection Process
Was Inadequate


            The Authority’s management did not implement an effective internal control
            process that ensured units met minimum housing quality standards and quality
            control inspections complied with requirements. The Authority’s internal control
            process did not include adequate policies and procedures that ensured compliance
            with HUD requirements.

            The inspectors did not identify all violations and passed units with housing quality
            violations. Several deficiencies existed at the time of the Authority’s most recent
            inspection, but the inspectors did not report them. In one unit, there were 15
            preexisting conditions that the Authority inspected and did not identify. In
            another unit, there were three preexisting conditions that the Authority inspected
            and passed 22 days before our inspection. Additionally, in 10 of 66 instances,
            inspectors identified deficiencies but improperly passed the units.

            The Authority’s procedures for performing quality control inspections were
            inadequate. The Authority’s quality control inspection procedures did not require
            a random selection from the universe of inspections performed. The Authority
            selected the units for quality control inspections based on the days the quality
            control reviewers were available. The Authority also did not require that
            unannounced quality control inspections be performed. The Section 8 and Leased
            Housing Manager or an independent contractor performed the quality control
            inspections. The Authority’s inspectors were told in advance which inspections
            would be selected. When the Section 8 and Leased Housing Manager performed
            the quality control inspections, he accompanied the Authority’s inspector and
            performed the quality control review at the same time the inspector was
            performing his review. The independent contractor may or may not accompany
            the Authority’s inspector, and in some cases would perform the quality control
            inspection before the inspector performed the initial inspection. In addition, the
            quality control reviewers did not prepare a written review of the quality of the
            inspector’s work. In addition, the performance appraisals used by the Authority
            did not address the quality of the inspector’s work.

            Authority officials stated that the procedures were established so the residents
            would not have to be available another day to have their unit reinspected and so
            that repairs noted during the two inspections could be presented to the owner in
            one document.

            Federal regulations at 24 CFR [Code of Federal Regulations] 985.2(b) state that
            the public housing authority’s quality control sample means an annual sample of
            files or records drawn in an unbiased manner and reviewed by a supervisor or


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                                             9
        other qualified person to determine whether the work documented in the files and
        records conforms to the program standards.

        In addition, 24 CFR [Code of Federal Regulations] 985.3(e) states that for
        housing quality control inspections, the reinspected sample is to be drawn from
        recently completed housing quality standards inspections and are to be drawn to
        represent a cross section of neighborhoods and inspectors.

        In addition, 24 CFR [Code of Federal Regulations] 982.54(a) requires the public
        housing authority to adopt a written administrative plan that establishes local
        policies for administration of the program in accordance with HUD requirements.

        Finally, 24 CFR [Code of Federal Regulations] 982.54(d)(22) states that the
        public housing authority administrative plan must cover policies, procedural
        guidelines, and performance standards for conducting required housing quality
        standards inspections.

        After our audit, the Authority began taking actions to address the problems with the
        unit inspections and quality control inspections. Authority officials have developed
        additional procedures regarding the Authority’s unit inspections and quality control
        inspection processes. They are also notifying the landlords of the housing quality
        standards deficiencies identified in our review and will inspect the units to verify
        that repairs were completed.

        Because the Authority did not have adequate internal controls, it made housing
        assistance payments for units that did not meet housing quality standards. While
        the Authority has developed new procedures for performing unit inspections and
        quality control inspections, the Authority has to complete all inspections under an
        improved inspection process. The Authority must emphasize the importance of
        housing quality standards and implement policies and procedures that ensure it
        complies with HUD requirements and gives the tenants the opportunity to live in
        decent, safe, and sanitary conditions. By continuing to make necessary
        improvements, the Authority will ensure that at least $10.4 million in Section 8
        funds will be used on units that meet housing quality standards.




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Recommendations

          We recommend that the director, Office of Public and Indian Housing,

          1A.     Require the Authority to inspect the 58 units that did not meet housing
                  quality standards to verify that the owners took appropriate corrective
                  actions to make the units decent, safe, and sanitary. If appropriate actions
                  were not taken, the Authority should abate the rents or terminate the housing
                  assistance payment contracts.

          1B.     Require the Authority to develop and implement an internal control plan
                  and policies and procedures, to include retraining the Authority inspectors
                  and monitoring the inspectors’ workload to ensure that units meet housing
                  quality standards and inspections meet HUD requirements to prevent an
                  estimated $10.4 million from being spent on units that are in material
                  noncompliance with standards.

          1C.     Require the Authority to develop and implement quality control inspection
                  procedures for selecting and reinspecting units, and evaluating the
                  inspectors’ work.




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                             SCOPE AND METHODOLOGY

Our audit objective was to determine whether the Authority’s Section 8 units met housing quality
standards in accordance with HUD requirements.

To accomplish our audit objectives, we reviewed the following:

•       Applicable laws, regulations, and other HUD program requirements;

•       The Authority’s Section 8 policies, procedures, and administrative plan;

•       Minutes from the board of commissioners meetings;

•       The Authority’s previous inspection reports; and

•       The Authority’s latest independent public accountant report and HUD program
        monitoring reviews.

We interviewed the Birmingham, Alabama, Office of Public Housing program officials and
Authority management and staff. We inspected a sample of 66 units with the HUD Birmingham
Office of Public Housing staff and the Authority’s inspectors. We performed the inspections
April 3 through April 25, 2006.

We obtained a download of the Authority’s active units from the housing assistance payment
register for February 2006 1 . There were 3,816 active units as of February 1, 2006. We used a
statistical software program to select a random statistical sample of the 3,816 tenants. Based on
a confidence level of 90 percent, a precision level of 10 percent, and an assumed error rate of 50
percent, the software returned a statistical sample of 66 units with a random selection start. We
used the software to generate 66 additional sample units to be used as replacements if needed.

Projecting the results of the 58 failed units in our statistical sample to the population indicates

The lower limit is 81.33 percent x 3,816 units = 3,103 units not meeting housing quality
standards.
The point estimate is 87.88 percent x 3,816 units = 3,354 units not meeting housing quality
standards.
The upper limit is 94.43 percent x 3,816 units = 3,603 units not meeting housing quality
standards.

We evaluated the 58 units that did not meet housing quality standards to identify those that were
in material noncompliance. Based on our judgment, we determined 38 units were in material

1
 To achieve our audit objectives, we relied in part on computer-processed data contained in the Authority’s
database. Although we did not perform a detailed assessment of the reliability of the data, we did perform a
minimal level of testing and found it to be adequate for our purposes.

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noncompliance with housing quality standards because of the overall poor condition of the unit.
Therefore, one of the failed conditions was a preexisting condition that was not reported at the
time of the Authority’s last inspection, and/or the unit had inadequate repairs, and/or one of the
failed conditions was caused by deferred maintenance. (See appendix C)

Projecting the results of the 38 units that were in material noncompliance with housing quality
standards to the population indicates

The lower limit is 47.66 percent x 3,816 units = 1,818 units in noncompliance with minimum
housing quality standards.
The point estimate is 57.58 percent x 3,816 units = 2,198 units in noncompliance with minimum
housing quality standards.
The upper limit is 67.50 percent x 3,816 units = 2,575 units in noncompliance with minimum
housing quality standards.

Using the lower limit and the average annual housing assistance payments for the population
based on the Authority’s February 2006 housing assistance payment register, we estimated the
Authority spent at least $10,428,048 (1,818 units x $478 average monthly housing assistance
payment x 12 months) for units that were in material noncompliance with housing quality
standards. The 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 recommendations.

Our audit generally covered the period July 1, 2004, through February 28, 2006. We expanded
our audit period as needed to accomplish our objectives. We performed our on-site work from
February through May 2006 at the Authority’s offices in Birmingham, Alabama, and the
Birmingham field office.

We performed our review in accordance with generally accepted government auditing standards.




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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:

              •   Compliance with laws, regulations, policies, and procedures that management
                  has implemented to reasonably assure that resource use is consistent with laws
                  and regulations.

              •   Policies and procedures that management has implemented to reasonably
                  assure that resources are safeguarded against waste, loss, and misuse.

              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 item is a significant weakness:

              •       The Authority did not have adequate internal controls to ensure that
                      Section 8 units met housing quality standards (see finding 1).



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                                       APPENDIXES

Appendix A

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


                                                                Funds to be put
                    Recommendation                               to better use 1/
                            1B                                    $ 10,428,048
                                                                    _________
                           Total                                  $ 10,428,048


1/      Recommendations that funds 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 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 Authority implements our
        recommendations, it will cease to incur Section 8 costs for units that are not decent, safe,
        and sanitary. This action will instead expend those 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.




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                                                15
Appendix B

        AUDITEE COMMENTS AND OIG’S EVALUATION


Ref to OIG Evaluation   Auditee Comments


Comment 1




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Comment 1




Comment 2




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 Comment 3




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Comment 4




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                           OIG Evaluation of Auditee Comments


Comment 1     We maintain that the Authority did not have adequate controls over the inspection
              and quality control inspection processes. We agree that some of the items
              identified may have occurred after the inspectors performed their inspections.
              However, the units we cited as failing was based on a combination of
              deficiencies. We found the inspectors improperly passed units with housing
              quality standards violations. We also found the inspectors passed units with
              inadequate repairs and deferred maintenance. The deficiencies were cited
              because they pose potential fire hazards (e.g., lawn mower located near gas and
              fire sources), unsanitary conditions (e.g., stopped up commode and sink), and an
              electrical hazard (e.g., thermostat had exposed electrical wiring) to the family.


Comment 2     We found that the Authority had procedures but they were inadequate. The
              Authority should have also addressed the Code of Federal Regulations
              requirements in their procedures because they include quality control inspection
              sampling methodology and performance standards for conducting housing quality
              standards inspections. In addition, the most objective way of reviewing an
              inspector's everyday work is to inspect the unit after the inspector has completed
              the inspection and does not think it will be inspected. Following behind an
              inspector without his knowledge will give the Authority the best indicator of the
              seasoned inspector's work product.


Comment 3 We agree that the HUD Inspection Form states that the outlets must be working,
          but it also states that outlets must be properly installed and that improper types of
          wiring and connections could pose electrical hazards. We also found similar
          requirements cited in Section 3 of the Inspection Manual. The Code of Federal
          Regulations 982.401(f) states that electrical outlets must be in proper operating
          condition. It also states that fixtures and wiring must ensure safety from fire.

              In addition, Chapter 10 of the Housing Choice Voucher Program Guidebook
              states that electrical fixtures and wiring must not pose a fire hazard, the PHA must
              be satisfied that the electrical system is free of hazardous conditions, including
              exposed, uninsulated, or frayed wires, improper connections, improper insulation
              or grounding of any component of the system.

              Based on the regulations, the electrical outlets have to be safe. When a landlord
              replaces an ungrounded outlet with a grounding type outlet, but that outlet is not
              connected to a ground that makes the outlet unsafe. As a result, the electrical
              outlets were not properly installed and pose a hazardous condition for the family.


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Comment 4   Interior doors - We agree the conditions of some interior doors cited during our
            inspections should not be included as housing quality standards violations. We
            adjusted our report to eliminate the cited violations for some of the interior doors.
            However, the remaining interior doors cited are not safe (i.e. falling off the
            hinges, splinting, and peeling) and could cause harm to the family.

            Circuit breaker box door - We agree the circuit breaker box door not closing is not
            a housing quality standards violation, since there were no exposed electrical
            contacts. We adjusted our report to eliminate this previously cited violation.

            Light over bathroom shower not working - We agree that since there was a
            working light fixture in the bathroom, we adjusted our report to eliminate the
            previously cited violation.

            Smoke detector not working - We agree there were working smoke detectors on
            the same level for five units cited. We adjusted our report to eliminate the
            previously cited violations.

            Peeling paint - The units cited for lead based paint hazard did have children under
            age six living in the units. Also, the deteriorated paint was cited because the
            scaling, peeling, chipping, or loose paint was caused by water damage, or in an
            area where the family could be harmed by falling plaster.

            TV cable blocking door and wire scattered - The television cable and wires
            scattered about the apartment pose a tripping hazard for the family.

            Operation of bathroom vanity drawer - The Authority previously cited the missing
            bathroom vanity drawer as a deficiency in its prior inspection. We found the
            drawer had been replaced but it did not work properly. As a result, the tenant
            could not fully close the vanity drawer, which could cause bodily harm to the
            tenant.

            Dryer not vented to outside - The dryer should be properly ventilated to prevent
            moisture and dust from building up in the unit.

            Fascia needs paint - The deteriorated paint was cited because of scaling, peeling,
            chipping, or loose paint caused by water damage. The units we cited for lead
            based paint hazard were for units where children under age six resided.

            Crawl space door broken - The unsecured/damaged crawl space door could allow
            small children, animals, and unauthorized persons access to the area underneath
            the home.

            Flies in the basement - The item was cited as a violation because the flies in the
            basement pose an unsanitary condition for the family.


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         HW discharge not piped to outside - The hot water discharge pipe was cited
         because its location presents a hazard to the family. The pipe was not installed in
         such a manner as to protect the family from potential scalding.

         Improper front door lock - We agree the condition of the front door lock is not a
         housing quality standards violation. We adjusted our report to eliminate this
         previously cited violation.

         Exterior windowsills - The exterior windowsills were cited as a violation because
         of the rust and deterioration caused by water damage that did not protect the unit’s
         interior. The HUD Inspection Form states that all windows should be free of
         signs of severe deterioration. The Housing Choice Voucher Guidebook also
         states that the windows must adequately protect the unit's interior from the
         weather.

         Outbuildings - The outbuilding was cited as a violation because the damaged door
         to the exterior laundry room could cause bodily harm to the family. In addition,
         the deficiency is a violation of site and neighborhood standards. The door is
         splintering and falling off the hinges. The damaged door also could pose a
         security threat to the family. The HUD inspector noted that the lock was broken
         which could allow unauthorized access to the home.

         All windows in house covered by plastic - We cited the windows as a violation
         because they do not adequately protect the unit’s interior from the weather.

         Although we made the appropriate adjustments, the adjustments did not have an
         overall effect on the 38 failed units in material noncompliance with housing
         quality standards.




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                                          23
Appendix C

  SCHEDULE OF UNITS IN MATERIAL NONCOMPLIANCE
        WITH HOUSING QUALITY STANDARDS


      Item           Preexisting        Inadequate    Deferred
     number          conditions           repairs    maintenance
        1                X                                X
        2                X                                X
        3                X                  X             X
        4                X                  X             X
        5                X                                X
        6                X                                X
        7                X                                X
        8                X                                X
        9                X                                X
       10                X                                X
       11                X                                X
       12                X                  X             X
       13                X                                X
       14                X                                X
       15                X                  X             X
       16                X                                X
       17                X                                X
       18                X                  X             X
       19                X                                X
       20                X                                X
       21                X                                X
       22                X                  X             X
       23                X                                X
       24                X                                X
       25                X                                X
       26                X                                X
       27                X                                X
       28                X                                X
       29                X                                X
       30                X                                X



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  Item              Preexisting        Inadequate    Deferred
 number             conditions           repairs    maintenance
   31                   X                  X             X
   32                   X                                X
   33                   X                                X
   34                   X                                X
   35                   X                                X
   36                   X                                X
   37                   X                                X
   38                   X                                X




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