oversight

Lubbock Housing Authority's, Lubbock, Texas, Lack of Management Controls Resulted in Section 8 Units Not Meeting Housing Quality Standards

Published by the Department of Housing and Urban Development, Office of Inspector General on 2006-10-16.

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

                                                                  Issue Date
                                                                           October 16, 2006
                                                                  Audit Report Number
                                                                               2007-FW-1001




TO:        Justin R. Ormsby
           Director, Office of Public Housing, 6APH



FROM:      Frank E. Baca
           Regional Inspector General for Audit, Fort Worth Region, 6AGA

SUBJECT: Lubbock Housing Authority’s, Lubbock, Texas, Lack of Management Controls
           Resulted in Section 8 Units Not Meeting Housing Quality Standards


                                   HIGHLIGHTS

 What We Audited and Why

         We audited the Lubbock Housing Authority’s (Authority) Section 8 Housing Choice
         Voucher program as part of our strategic plan. Our objective was to determine
         whether the Authority’s Section 8 units met housing quality standards and if not,
         determine the extent, cause, and impact of the housing quality standards unit failures
         on the Authority’s Section 8 Housing Choice Voucher program.


 What We Found


         Of the 61 units we inspected, 47 (77 percent) failed inspections, and 30 (49 percent)
         were materially noncompliant with housing quality standards. The failures occurred
         because the Authority’s Section 8 program lacked effective management and controls
         over the inspection process; specifically, the program had inadequate written policies
         and procedures, poor inspections, no quality control system, and negative staffing
         issues. As a result, the Authority housed families in units that did not meet the U.S.
         Department of Housing and Urban Development’s (HUD) standards of decent, safe,
        and sanitary housing. If the Authority does not implement effective management and
        controls, we estimate it will spend more than $1.2 million in the next 12 months on
        the estimated 266 units expected to be materially noncompliant with HUD’s housing
        quality standards.


What We Recommend


        We recommend that HUD require the Authority to ensure that all 47 units that failed
        the Office of Inspector General’s (OIG) inspections meet housing quality standards.
        Further, we recommend that HUD require the Authority’s management to implement
        procedures and controls over its Section 8 inspection process to ensure that all of its
        units meet housing quality standards.

        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 provided a draft to the auditee on September 20, 2006, and requested a response
        by October 5, 2006. The authority provided a written response on October 5, 2006,
        and did not disagree with our finding. The auditee’s response also detailed the steps
        it has begun and plans to take to address the deficiencies. HUD’s Fort Worth Office
        of Public Housing agreed with our finding and indicated they will submit their
        management decisions after the final issuance of the report. 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 Objectives                                                           4

Results of Audit
      Finding: Authority’s Lack of Management Controls Results in Section 8 Units   5
      Not Meeting Housing Quality Standards

Scope and Methodology                                                               13

Internal Controls                                                                   16

Appendixes
   A. Schedule of Questioned Costs and Funds to Be Put to Better Use                17
   B. Auditee Comments and OIG’s Evaluation                                         18




                                            3
                      BACKGROUND AND OBJECTIVES


The City of Lubbock (City) is the ninth largest city in Texas and the largest city in west Texas. The
Lubbock Housing Authority (Authority) was established in 1939 to provide decent, safe, and
sanitary housing for families of low to moderate income. The Authority is governed by a seven-
member board of commissioners appointed by the mayor for two-year terms. It administers both
public housing and Section 8 programs. Its Section 8 Housing Choice Voucher program consists of
852 vouchers. The Authority’s staff works and maintains administrative records and tenant files in
its main office at 1708 Avenue G in Lubbock, Texas, except for its maintenance staff, which works
and maintains its records at 1329 East 19th Street in Lubbock.

During January 2006, the U.S. Department of Housing and Urban Development (HUD) Office of
Public Housing in Fort Worth identified the Authority as a candidate for an Office of Inspector
General (OIG) audit. The Office of Public Housing considered the Authority troubled and placed it
under a memorandum of agreement to improve its operations. The Office of Public Housing also
questioned whether the Authority had the capacity to operate its housing programs effectively. The
previous executive director had left the Authority in November 2005. A deputy director served as
the interim executive director from November 2005 until April 2006 when the City assigned one of
its managers to be the executive director of the Authority for up to two years. The Office of Public
Housing supported the assignment. Both the Office of Public Housing and the City believe that the
new executive director will help the Authority improve its operations.

We selected the Authority’s Section 8 Housing Choice Voucher program for audit as part of our
strategic plan. Our objective was to determine whether the Authority’s Section 8 Housing
Choice Voucher units met housing quality standards and if not, to determine the extent, cause,
and impact of the housing quality standards unit failures on the Authority’s Section 8 Housing
Choice Voucher program. This is the first of three audit reports on the Authority’s Section 8
program.




                                                  4
                                        RESULTS OF AUDIT

Finding: Authority’s Lack of Management Controls Results in Section 8
Units Not Meeting Housing Quality Standards
Of the 61 statistically selected sample units that we inspected, 47 (77 percent) failed inspection,
and 30 (49 percent) were materially noncompliant with housing quality standards. The units did
not meet standards because the Authority’s Section 8 program had ineffective management and
controls over the inspection process, including (1) ineffective or non-existent written policies and
procedures, (2) ineffective and poorly documented inspections, (3) no quality control system,
and (4) adverse staffing issues. As a result, the Authority housed families in units that did not
meet HUD’s standards of decent, safe, and sanitary housing. If the Authority does not establish
effective management and controls, we estimate that over the next year it will pay more than
$1.2 million in Section 8 housing assistance payments for units with material housing quality
standards violations.



    The Authority’s Section 8 Units
    Did Not Meet HUD’s Housing
    Quality Standards


              Our inspections found a total of 247 housing quality standards violations in the 47
              units that failed inspection. Projecting the results of the overall failure rate to the
              Authority’s universe of 680 units shows that at least 466 of the units or 68.6 percent
              would not meet minimum housing quality standards. In addition, we determined that
              30 of the 61 sample units or 49 percent were materially noncompliant with housing
              quality standards. 1 Projecting the results of the 30 significant failures to the universe
              of 680 units shows that a minimum of 266 of the Authority’s units would fail an
              inspection with violations that are materially noncompliant with HUD’s housing
              quality standards. If corrective action is not taken, we estimate that the Authority will
              spend more than $1.2 million in the next 12 months on these 266 units that are
              materially noncompliant. 2




1
      See the Scope and Methodology section of this report for our definition of and method of determining which
      units were materially noncompliant.
2
      See the Scope and Methodology section of this report for our method of calculating funds to be put to better
      use.


                                                          5
The Section 8 Program Lacked
Effective Management

        The Authority’s Section 8 program lacked effective management because the
        Authority’s prior management overrode, ignored, or failed to establish controls over
        the inspection process. This led to 1) ineffective or nonexistent written policies and
        procedures, 2) ineffective and inconsistent inspections, 3) no quality control system,
        and 4) adverse staffing issues. These issues are discussed more fully in the following
        sections. The lack of management and controls caused a number of failures in the
        inspection processes, such as inspectors not:

                   •   Performing inspections, not performing them in a timely manner, or
                       not following up on failures in a timely manner;
                   •   Adequately reviewing external conditions of units;
                   •   Noting obvious fail items on inspections;
                   •   Identifying health and safety fail items;
                   •   Knowing what constitutes a fail item;
                   •   Filling out inspection forms consistently;
                   •   Maintaining accurate and organized records of inspections, which
                       resulted in inspectors conducting multiple inspections of the same
                       units; and
                   •   Updating HUD’s Public and Indian Housing Information Center
                       database system through Form HUD-50058.

        As a result, the Authority housed families in units that did not meet the minimum
        standards for decent, safe, and sanitary housing.


The Authority’s Written
Procedures Were Lacking or
Ineffective

        The Authority did not have written procedures or policies to ensure that inspections
        were performed or performed in a timely manner, failed inspections were followed up
        on, or rents were abated or tenants terminated if the inspection failures were not
        corrected in a timely manner. The Authority’s Section 8 administrative plan was the
        only written policy the Authority had that addressed housing quality standards and the
        inspection process. However, the administrative plan lacked detail, and the Authority
        did not always follow the policies contained in it.

        The Authority Lacked Procedures for Tracking and Monitoring Inspections

        The Authority did not have documented procedures in place to ensure that it
        maintained accurate and organized records of inspections. The Authority did not


                                             6
clearly define to its staff their responsibilities for maintaining the files and performing
the inspections and what information needed to be maintained or tracked. As a result,
it was unable to locate and provide copies of the previous inspections for 11 of the 61
units selected for inspection. In addition, the former Section 8 administrator had no
log, reports, or system to track inspections to ensure that they were performed in a
timely manner, followed up on if the unit failed, and entered into HUD’s Public and
Indian Housing Information Center database system. Management and staff did not
know whether units were overdue for an inspection or reinspection. Based on a
review of the information available, the Authority had not inspected 21 of the 61
sample units annually. Further, for the 61 units inspected, the Authority had not
updated the HUD system to show the unit’s last passed inspection date for one to
three years for 29 of the units, meaning that more than a year could have passed
between annual inspections. Both the prior executive director and the Section 8
administrator received error reports for HUD system data, but it was not until the new
executive director was hired that headway was made in clearing the problems.
Authority staff also said that they found inspection reports in the office of the former
Section 8 administrator that had not been filed or entered into the Authority’s
computer system, which resulted in some inspections being duplicated. During our
inspections, one tenant confirmed that her unit had two annual inspections within the
last year.

The Authority Did Not Ensure That Failed Units Were Repaired and Reinspected
within 30 Days

In addition to not being able to track or locate inspections, the Authority lacked a
process to ensure that units which failed inspection were repaired and reinspected
within 30 days as required by the Authority’s administrative plan. Four units we
inspected had previous failed inspections, and a reinspection was either not performed
or not documented. A Section 8 inspector admitted to sometimes allowing owners to
submit written proof of repairs made to failed units rather than performing an actual
reinspection, a practice that violated the Authority’s administrative plan. The Section
8 administrator also did not have a report or other tracking process to ensure that
abatement or termination occurred for failed units if repairs were not made within 30
days of the original failed inspection as required by the Authority’s administrative
plan. Further, the Authority’s inspector admitted to being unable to meet the 30-day
reinspection requirement because the Authority was so far behind. Out of the 61
units in our sample, the Authority did not ensure that 14, which had failed a previous
Authority inspection, were corrected within the required 30-day period. Instead, the
Authority took an average of 56 days to follow up and ensure the units were repaired.
The Authority did not abate the rent or terminate the tenants for any of the 14 units
because it did not take such action if it was the Authority’s fault that the unit had not
been reinspected. In addition, the Authority could not ensure that failed units were
reinspected in a timely manner as it did not reinspect 42 of the 47 fails within 30
days.




                                      7
Inspections Were Ineffectively
Performed and Poorly
Documented


         Section 8 inspectors passed substandard units because their inspections were not
         thorough and the Authority had not clearly defined what constituted a fail item. Further,
         the inspectors did not adequately document the results of their inspections or
         consistently complete the inspection forms.

         Our inspections identified housing quality standards fail items that had obviously existed
         for some time at the unit, but the Authority’s inspectors had not detected or required
         correction of the issues. The Authority’s inspectors did not ensure that long-standing
         conditions, like the following sewer leak, chipping paint, rotted window sills, and unsafe
         air conditioning unit, were corrected.



                                                                             Unit occupied by the
                                                                             tenant and three
                                                                             children with raw
                                                                             sewage seeping from
                                                                             under the foundation.




                                                                             Unit occupied by the
                                                                             tenant and seven
                                                                             children, five of whom
                                                                             were age six or
                                                                             younger, with possible
                                                                             lead-based paint
                                                                             peeling on the front
                                                                             porch posts, which
                                                                             extended to the
                                                                             ground. This unit had
                                                                             passed inspection one
                                                                             month before our
                                                                             inspection.




                                               8
                                                                   Unit in which the
                                                                   window sills on the
                                                                   entire house’s
                                                                   exterior were
                                                                   deteriorated and dry
                                                                   rotted.




                                                                     Unit in which the
                                                                     air conditioner was
                                                                     improperly
                                                                     supported.




One tenant we interviewed stated that the previous inspector never went outside the unit
during the inspection and the sewer leak pictured above had existed for two years.
However, the Authority’s current inspector indicated that he had sufficient time to
perform inspections, including performing a general review of the exterior conditions of
a unit.

The Authority’s administrative plan defines the inspection standards a unit must meet by
stating that a unit will meet the minimum housing quality standards as set forth in 24
CFR [Code of Federal Regulations] 982.401. These standards are quite broad.
Interviews with Authority staff, including management, showed differing opinions on


                                     9
        what constituted a fail. Thus, the inspectors might not fail a unit for something that
        management or another inspector believes should fail and vice versa.

        The Authority also did not ensure that its inspectors completely and consistently
        documented the results of their inspections. Of the 61 units we inspected, 41 had at least
        one of the following errors on the unit’s prior inspection forms. The inspection

               •   Was not marked pass, fail, or inconclusive;
               •   Failed to identify the inspector;
               •   Did not include the date of the inspection;
               •   Did not identify the type of inspection (initial, reinspection, or special); or
               •   Failed to note the tenant’s name.

        In some cases, the only way to determine whether a unit had failed the previous
        inspection was that the Authority had issued a deficiency letter to the owner.
        Apparently, these errors and the inconsistencies in failures went undetected because the
        Section 8 administrator did not review the inspection reports.

There Was No Quality Control
System in Place


        Although its administrative plan contained steps for quality control inspections, the
        Authority did not have a system in place to ensure that its Section 8 staff performed
        them as required by HUD’s regulations and its administrative plan. Instead, former
        Authority management overrode or ignored the controls, which were designed to
        monitor the effectiveness of the Authority’s inspection process. Consequently, the
        Authority did not adequately perform or document quality control inspections and
        cannot support its Section 8 Management Assessment Program (SEMAP) self-
        certification and score.

        The former Section 8 administrator either did not perform the quality control
        inspections or performed them inadequately. The former Section 8 administrator
        stated that she performed quality control inspections; however, she was unable to
        provide any documentation to support this statement, and other Authority staff stated
        that the Section 8 administrator did not perform the inspections. If she performed the
        quality control inspections, they served no useful purpose as she did not document the
        results of the inspections or discuss the results with the inspectors. As a result, the
        inspectors did not receive feedback as to whether they performed their inspections
        properly and in compliance with HUD’s and the Authority’s requirements.

        The Authority also cannot support its September 2005 Section 8 Management
        Assessment Program self-certification that it had performed the required annual
        sample of quality control inspections. Previous Authority management was
        apparently unaware that support for the quality control reviews did not exist because



                                              10
         the former Section 8 administrator stated that management had never requested to see
         the reports on quality control.

Staffing Issues Had a
Negative Impact


         Ineffective management also led to high staff turnover and a lack of direction and
         training. The Authority has experienced significant turnover in management in the
         last 10 months. The previous executive director left in November 2005, and the City
         assigned one of its employees to be executive director in April 2006. The director of
         finance, who oversaw the Section 8 department, left in May 2006, and the Section 8
         administrator resigned at the end of July 2006. In addition, during the last few years,
         the Authority’s Section 8 department has seen both a decrease in size and a loss of
         experienced staff. Within the last 12 months, 13 people have worked in the Section 8
         department and, as of August 2006, the department had a staff of four. None of the
         current staff has been there more than eight months.

         The Authority’s operational procedures have also fluctuated over time. Originally,
         the Authority had trained inspectors performing all of its inspections. At one point,
         though, the Authority began requiring caseworkers to perform inspections due to
         turnover. However, the Authority did not adequately train the caseworkers to
         perform the inspections, and the caseworkers were reluctant to perform them, fearing
         for their safety. The Authority currently has a single inspector. Training is still an
         issue, as the current inspector has not received specific training on HUD’s housing
         quality standards.

 The Authority Has Taken
 Steps to Address the Problems

         The current executive director admitted that the Authority had no controls and has
         changed the operations of the Section 8 program. The Authority is working with
         HUD and another housing authority to improve its operations. The Authority is also
         working to decrease the number of inspections that are outstanding and to ensure that
         reinspections are performed in a timely manner. In addition, the Authority’s
         inspector is using a handheld computer to perform and document inspections, which
         should significantly reduce documentation problems. The executive director and staff
         indicated that there has been a significant improvement in morale at the Authority,
         and HUD staff indicated that the Authority is improving.




                                             11
Conclusion


        Since the Authority did not have effective management to establish procedures and
        controls to effectively operate and monitor its Section 8 program, tenants lived in
        units that were not decent, safe, and sanitary. The Authority’s new management has
        taken steps to correct the problems. However, HUD needs to ensure that the
        Authority’s management establishes and implements policies, procedures, and
        controls that are consistently followed to prevent tenants from living in unsanitary
        and unsafe units. Further, Authority management needs to monitor the controls over
        the inspection quality control process to ensure that they are not overridden or
        ignored. The Authority’s management also needs to revise its previous Section 8
        Management Assessment Program score for quality control inspections and ensure
        that future certifications concerning quality control inspections are supported by
        adequate documentation.

Recommendations



        We recommend that the director of HUD’s Fort Worth Office of Public Housing require
        the Authority to

        1A. Ensure that all 47 units that failed standards when inspected by OIG meet
            standards. If the units cannot be made decent, safe, and sanitary, either abate
            the unit if the fail item is owner related or terminate the tenant’s voucher if the
            fail item is tenant caused.

        1B. Establish and implement policies, procedures, and controls over its entire
            inspection process and systems that are consistently followed to prevent tenants
            from living in indecent, unsanitary, and unsafe units.

        1C. Revise its previous Section 8 Management Assessment Program score for
            quality control inspections and ensure that future certifications concerning
            quality control inspections are supported by adequate documentation.




                                             12
                        SCOPE AND METHODOLOGY

To accomplish our objective, we

   •   Obtained and reviewed relevant HUD regulations and the Authority’s administrative
       plan.

   •   Selected a statistical sample of 61 of the Authority’s units to inspect from HUD’s Public
       and Indian Housing Information Center system, which is documented below.

   •   Obtained and reviewed, if available, the Authority’s previous inspection reports and
       HUD data for the sample units to determine whether the unit 1) passed its last inspection,
       2) was inspected annually, and 3) had a completed inspection report.

   •   Inspected the 61 units with a HUD staff person and the Authority’s inspector to
       determine whether the units met housing quality standards. We then compiled and
       summarized the results as discussed below.

   •   Reviewed the 47 fails with the Authority’s staff more than 30 days after the inspections
       had been completed to determine whether they had been reinspected according to the
       Authority’s plan.

   •   Conducted interviews with Authority staff, Office of Public Housing staff, and program
       tenants.

 Statistical Sample Selection and
 Methodology


          To obtain a statistical sample, we obtained a download of all of the Authority’s
          current tenants from HUD’s Public and Indian Housing Information Center system as
          of March 9, 2006. We used the data although we were unable to match the data 100
          percent to the Authority’s housing assistance payments register. The HUD data
          download resulted in a universe that consisted of 680 current tenants. OIG’s
          Information Systems Audit Division used the Statistical Toolbox software application
          to select the sample size based on the following sampling criteria: a 90 percent
          confidence level, a 50 percent expected error rate, and a 10 percent desired precision
          rate. Statistical Toolbox established a total of 61 tenants’ units to inspect. We also
          used Statistical Toolbox to generate additional units to be used as replacements units.
          We inspected 61 units from June 5 to June 14, 2006, with a staff person from HUD’s
          Fort Worth Office of Public Housing and the Authority’s inspector, to determine
          whether the Authority’s units met HUD’s housing quality standards. We replaced
          eight of the original units because either the tenants had moved or the unit was not
          accessible.



                                               13
        OIG’s Information Systems Audit Division used Statistical Toolbox to project the
        results of the 47 failed units to the universe of 680 units as follows:

        •   The lower limit is 68.6 % x 680 = 466 units not meeting housing quality
            standards, and
        •   The upper limit is 85.5 % x 680 = 581 units not meeting housing quality
            standards.

        Using the same software, OIG’s Information Systems Audit Division projected the
        results of the 30 units determined to be materially noncompliant with housing quality
        standards to the universe of 680 units as follows:

        •   The lower limit is 39.13 % x 680 = 266 units materially noncompliant with
            housing quality standards, and
        •   The upper limit is 59.23 % x 680 = 403 units materially noncompliant with
            housing quality standards.


Determination of Materially
Noncompliant Units


        After we conducted our inspections, we compiled the results defining a materially
        noncompliant unit as one that contained

        1. Health and safety failures including tripping hazards, falling hazards, exposed
           wiring, carbon monoxide leaks, and water leaks and/or

        2. Failure items that obviously existed during the Authority’s prior inspection that the
           Authority did not note on the inspection form and that contained health and safety
           failures.

Determination of Funds to Be
Put to Better Use



        To calculate our estimate of funds to be put to better use, we determined the
        Authority’s average housing assistance payment for all 680 units during our audit
        period. We then multiplied the Authority’s average monthly payment per unit ($378)
        by the lower minimum of 266 units determined to be materially noncompliant to
        arrive at a monthly estimate of overpayment, which we then annualized. This
        resulted in a $1,205,989 estimate of funds to be put to better use (266 units X $378
        monthly average rent X 12 months =$1,205,989).




                                             14
Inspection Data in HUD’s
System Not Reliable


        We determined that the inspection data input by the Authority’s into its and HUD’s
        systems were not reliable. Our testing found instances in which HUD’s information
        did not match hard copy inspection information in the Authority’s files or the
        Authority did not have hard copy inspections to support the information in HUD’s
        system. As a result, we did not rely on the inspection data in HUD’s system unless
        the Authority had no other information available concerning a unit’s inspection.
        Instead, we relied on available hard copy information. Further, we only used the
        HUD inspection data for determining whether units had been inspected annually, and
        we qualified our statements in this report concerning that testing.

        We performed our on-site work between May 22 and August 9, 2006, at the Authority’s
        offices, located at 1329 East 19th Street in Lubbock, and at the various units selected for
        review. Our work covered the period of January 1, 2005, through April 30, 2006. We
        expanded the scope of our review as necessary. We performed our review in
        accordance with generally accepted government auditing standards.




                                              15
                              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:

              •   Effectiveness and efficiency of program operations – Policies and procedures
                  that management has implemented to reasonably ensure that a program meets its
                  objectives.
              •   Compliance with laws and regulations – Policies and procedures that
                  management has implemented to reasonably ensure that resources are used
                  consistent with laws and regulations.

           We assessed the relevant controls identified above.

           A significant weakness exists if management controls do not provide reasonable
           assurance that the process for planning, organizing, directing, and controlling program
           operations will meet the organization’s objectives.


 Significant Weaknesses


           Based on our review, we believe the following items are significant weaknesses:

              •       The Authority lacked effective management, controls, and written
                      procedures over its inspection process to ensure that its units complied
                      with HUD’s requirements, and
              •       The Authority lacked an effective quality control system that complied with
                      HUD’s Section 8 Management Assessment Program requirements.



                                                16
                                      APPENDIXES

Appendix A

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

                        Recommendation        Funds to be put
                            number            to better use 1/
                                1B                  $1,205,989




1/ 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 which 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 will instead expend those funds for units that meet
   HUD’s standards. Once the Authority establishes and successfully implements the
   recommended procedures and controls, this will be a recurring benefit. Our estimate reflects
   only the initial year of these recurring benefits.




                                               17
Appendix B

        AUDITEE COMMENTS AND OIG’S EVALUATION


Ref to OIG Evaluation   Auditee Comments




Comment 1




                         18
19
                           OIG Evaluation of Auditee Comments

Comment 1: The Authority did not disagree with our finding. Their response detailed the steps
it will take to address the deficiencies.




                                             20