Issue Date April 15, 2008 Audit Report Number 2008-PH-1007 TO: Dennis G. Bellingtier, Director, Office of Public Housing, Pennsylvania State Office, 3APH FROM: John P. Buck, Regional Inspector General for Audit, Philadelphia Regional Office, 3AGA SUBJECT: The Harrisburg Housing Authority, Harrisburg, Pennsylvania, Did Not Ensure That Its Section 8 Housing Choice Voucher Program Units Met Housing Quality Standards HIGHLIGHTS What We Audited and Why We audited the Harrisburg Housing Authority’s (Authority) administration of its housing quality standards inspection program for its Section 8 Housing Choice Voucher program based on the survey results of our recently completed audit of the Authority’s low-rent public housing and Section 8 Housing Choice Voucher programs. This is our second audit report issued on the Authority’s programs. The audit objective addressed in this report was to determine whether the Authority adequately administered its Section 8 housing quality standards inspection program to ensure that its program units met housing quality standards in accordance with U.S. Department of Housing and Urban Development (HUD) requirements. What We Found The Authority did not adequately administer its inspection program to ensure that its program units met housing quality standards as required. We inspected 52 housing units and found that 37 units did not meet HUD’s housing quality standards. Moreover, 35 of the 52 units had exigent health and safety violations that the Authority’s inspectors neglected to report during their last inspection. The Authority spent $34,113 in program and administrative funds for these 35 units. We estimated that over the next year if the Authority does not implement adequate procedures and controls to ensure that its program units meet housing quality standards, HUD will pay more than $884,000 in housing assistance and administrative fees for units with material housing quality standards violations. Program rents were not abated for units that failed the Authority’s housing quality standards inspections. Eleven units that failed inspections performed between January 2006 and July 2007 remained in failing status for more than two months. However, the Authority failed to abate the program rents or terminate the contracts for these units, resulting in an improper payment of $10,796 in housing assistance and administrative fees. What We Recommend We recommend that HUD require the Authority to ensure that housing units inspected during the audit are repaired to meet HUD’s housing quality standards, reimburse its program from nonfederal funds for the improper use of $34,113 in program funds for units that materially failed to meet HUD’s housing quality standards, and implement adequate procedures and controls to ensure that in the future, program units meet housing quality standards to prevent an estimated $884,917 from being spent annually for units with material housing quality standards violations. Further, we recommend that HUD require the Authority to reimburse its program $10,796 from nonfederal funds for the 11 units for which it did not abate payment or terminate the assistance contract in a timely manner and develop and implement management controls to ensure that employees comply with its policies and procedures concerning abatements. 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 report with the Authority during the audit and at an exit conference on February 28, 2008. The Authority provided written comments to our draft report on March 13, 2008. The Authority acknowledged that it needed to improve its inspection program and that it had implemented management improvements to address some of the issues addressed in the audit report. However, the Authority contested some of the violations that we identified, asserting that we overstated the amount of ineligible funds included in the report. 2 The complete text of the Authority’s response, along with our evaluation of that response, can be found in appendix B of this report. 3 TABLE OF CONTENTS Background and Objectives 5 Results of Audit Finding: Controls over Housing Quality Standards Were Inadequate 6 Scope and Methodology 17 Internal Controls 19 Appendixes A. Schedule of Questioned Costs and Funds to Be Put to Better Use 21 B. Auditee Comments and OIG’s Evaluation 22 4 BACKGROUND AND OBJECTIVES The Harrisburg Housing Authority (Authority) was established in 1938 under the Housing Authority Law of the Commonwealth of Pennsylvania to serve the needs of low-income, very low- income and extremely low-income families in the City of Harrisburg and to (1) maintain the availability of decent, safe and affordable housing in its communities; (2) ensure equal opportunity in housing; (3) promote self-sufficiency and asset development of families and individuals; and (4) improve community quality of life and economic viability. A five-member board of commissioners governs the Authority. The commissioners serve five-year terms on the board. The acting executive director of the Authority during the audit was Jerry Shenck. The Authority’s main administrative office is located at 351 Chestnut Street, Harrisburg, Pennsylvania. Under the Section 8 Housing Choice Voucher program, the Authority makes rental assistance payments to landlords on behalf of eligible low-income families. HUD compensates the Authority for the cost of administering the program through administrative fees. HUD authorized the Authority to provide leased housing assistance payments for more than 940 eligible households. HUD authorized the Authority the following financial assistance for housing choice vouchers: Amount Authority fiscal year Annual budget authority disbursed 2006 $4,227,108 $4,227,108 2007 $4,361,872 $4,361,872 Total $8,588,980 $8,588,980 HUD regulations at 24 CFR [Code of Federal Regulations] 982.305(a) state that a public housing authority may not execute a housing assistance contract until it has determined that the unit has been inspected and meets HUD’s housing quality standards. HUD regulations at 24 CFR 982.405(a) require public housing authorities to perform unit inspections before the term of the lease, at least annually during the assisted occupancy, and at other times as needed to determine whether the unit meets housing quality standards. HUD regulations at 24 CFR 982.404(a) state that if the owner fails to maintain the dwelling unit in accordance with HUD’s housing quality standards, the public housing authority must take prompt and vigorous action to enforce the owner obligations. The authority must not make any housing assistance payments for a dwelling unit that fails to meet HUD’s housing quality standards unless the owner corrects the defect within the period specified by the authority and the authority verifies the correction. Our audit objective was to determine whether the Authority adequately administered its inspection program to ensure that its program units met housing quality standards in accordance with HUD requirements. 5 RESULTS OF AUDIT Finding: Controls over Housing Quality Standards Were Inadequate The Authority did not adequately enforce HUD’s housing quality standards. Of 52 program units selected for inspection, 37 did not meet minimum housing quality standards, and 35 had material violations that existed before the Authority’s previous inspections. The Authority’s inspectors did not report 228 violations when they performed their inspections. Further, the Authority did not abate units that failed its housing quality standards inspections as required. The violations occurred because the Authority’s contracts with its inspectors coupled with a lack of quality controls created weakness in its inspection program, the Authority did not adequately address problems it had identified in the past with completed inspections, it did not routinely perform quality control inspections, and it contracted with individuals who did not have training in conducting housing quality standards inspections. The improper abatements occurred because employees disregarded policy and used their discretion in continuing to make housing assistance payments for failed units. As a result, the Authority spent more than $44,000 in program and administrative funds for units that materially failed to meet HUD’s housing quality standards. We estimate that over the next year, HUD will pay more than $884,000 in housing assistance for units with material violations of housing quality standards. Section 8 Tenant-Based Housing Units Were Not in Compliance with HUD’s Housing Quality Standards We statistically selected 52 units from unit inspections passed by the Authority’s inspectors during the period April 21 to July 20, 2007. The 52 units were selected to determine whether the Authority ensured that the units in its program met housing quality standards. We inspected the selected units between August 20 and August 29, 2007. Of the 52 units inspected, 37 (71 percent) had 320 housing quality standards violations. Additionally, 35 of the 52 units (67 percent) were considered to be in material noncompliance since they had exigent health and safety violations that predated the Authority’s last inspection and were not identified by an Authority inspector. Two of the 35 units had five violations that were noted on the Authority’s previous inspection report, and the Authority later passed the units, but during our inspection, it was determined that the violations had not been corrected. The 35 units had 233 total violations (including the five identified by the Authority but not corrected) that existed before the Authority’s last inspection report. The Authority’s inspectors did not identify or did not report 228 violations that existed at the time of their most recent inspections. HUD regulations at 24 6 CFR [Code of Federal Regulations] 982.401 require that all program housing meet HUD’s housing quality standards at the beginning of the assisted occupancy and throughout the tenancy. The following table categorizes the 320 housing quality standards violations in the 37 units that failed the housing quality standards inspections. Number of Number Percentage Type of violation violations of units of units Structure and materials 130 28 54 Illumination and electricity 56 29 56 Space and security 56 23 44 Food preparation and refuse disposal 22 11 21 Smoke detectors 21 15 29 Sanitary facilities 20 14 27 Interior air quality 5 4 8 Thermal environment 4 4 8 Site and neighborhood 3 3 6 Sanitary condition 3 3 6 Total 320 We provided our inspection results to the Director of HUD’s Office of Public Housing, Pennsylvania State Office, and the Authority’s acting executive director during the audit. Housing Quality Standards Violations Were Identified The following pictures illustrate some of the violations we noted while conducting housing quality standards inspections at the Authority’s leased housing units. 7 Inspection #23: Mold is present in the basement bathroom on the vanity and wall. This violation was not identified during the Authority’s June 29, 2007, inspection. Inspection #47: A mouse hole and droppings are above the baseboard in the dining room. This violation was not identified during the Authority’s July 25, 2007, inspection. 8 Inspection #29: A leaking drain pipe from the kitchen is wrapped with duct tape in failed attempts to stop the leak. This violation was not identified during the Authority’s April 26, 2007, inspection. Inspection #29: There are exposed contacts on a furnace controller near the basement floor. This violation was not identified during the Authority’s April 26, 2007, inspection. 9 Inspection #23: Damage to plaster and missing Inspection #52: There is an unacceptable discharge ceiling tiles in the back bedroom on the second floor pipe on the water heater’s pressure relief valve that were caused by a leak in the roof of the adjacent leaves a gap through which escaping steam can scald abandoned unit. The violation was not identified a tenant. The pipe needs to be continuous to within a during the Authority’s June 29, 2007, inspection. minimum of six inches off the floor. This violation was not identified during the Authority’s July 5, 2007, inspection. Inspection #38: The cover plate is missing from the left/rear bedroom wall outlet. This violation was not identified during the Authority’s April 26, 2007, inspection. 10 Inspection #35: There is a loose carpet on the basement stairs, and a guardrail is needed on the open side of the staircase. This violation was not identified during the Authority’s April 26, 2007, inspection. Inspection #47: The banister protecting the stairway opening on the third floor is only 23 inches from the floor and insufficiently high for protection. Also, the handrail on the stairway to the third floor stops three steps short of the top. Neither of these violations was identified during the Authority’s July 25, 2007, inspection. 11 The Authority Lacked Controls to Ensure Compliance with HUD’s Housing Quality Standards Although HUD regulations and the Authority’s written policies and procedures required the Authority to ensure that its program units met housing quality standards, it failed to do so. This condition occurred because (1) the fee structure of the Authority’s contracts with its contracted inspectors coupled with a lack of quality controls created weakness in the Authority’s inspection program, (2) the Authority did not take action to address problems identified with the inspections completed by the contracted inspectors, (3) it did not routinely perform quality control inspections, and (4) it hired contractors who did not have training in HUD’s housing quality standards to perform inspections. The following paragraphs provide details. The Authority’s Contracts for Inspection Services and Lack of Controls Created Weakness in the Authority’s Inspection Program The Authority’s contracts with its inspectors stated that “the contractor will provide services on an as needed basis” and “the contractor will be compensated per unit for inspection services.” One inspector was paid a flat fee of $75 per unit 1 for inspection and any reinspections if the unit failed, and the other inspector was paid a flat fee of $49 per unit 2 for inspection and any reinspections if the unit failed. We believe that the inspectors’ flat fee arrangements coupled with the lack of quality controls (discussed in the following paragraphs) created a weakness in the Authority’s inspection program. The inspectors lacked incentive to identify all of the violations in the units that they inspected. This was demonstrated by the significant number of deficiencies that we identified during our inspections. Our inspection results showed the Authority’s inspectors passed 35 units during the prior four month period with a total of 233 preexisting deficiencies. These results provide the basis for the quality of the inspection work provided by the Authority’s inspectors. The Authority Did Not Adequately Address Concerns with Inspections The Authority’s Section 8 coordinator was aware of problems with the quality of the inspections completed by the inspectors but did not take sufficient action to address the problems. The Section 8 coordinator stated that she identified problems with the inspectors’ work when conducting quality control and complaint inspections. As part of the followup procedures for complaints, the Section 8 coordinator addressed problems identified during the complaint inspections with the inspector who had passed the unit during the last inspection. 1 This inspector had been providing inspection services to the Authority for more than 15 years. 2 This inspector provided inspection services to the Authority from March to July 2007. The Authority terminated its contract with this inspector on July 31, 2007, effective September 3, 2007. 12 The Section 8 coordinator also stated that, at other times, she counseled one of the inspectors regarding the quality of his inspections. The coordinator stated that the inspector was indifferent to the assessment of his work. The Section 8 coordinator did not document her discussions with the inspector. The coordinator stated that she was not responsible for enforcing the contracts. The Authority’s former executive director had hired the inspectors; therefore, the coordinator was reluctant to raise the issue with him. The coordinator stated that she discussed the inspector’s performance with the acting executive director, but she did not document the discussion. The Authority Did Not Routinely Perform Quality Control Inspections The Authority did not perform its required quality control inspections throughout the year. For 2007, the Authority’s Section 8 coordinator performed quality control inspections from January to March. No quality control inspections were conducted between March 23 and July 23, 2007. The Section 8 coordinator stated that no quality control reviews were conducted because staffing issues prevented them from being performed. Periodic quality control reviews performed within narrow timeframes may not provide sufficient assurance that inspectors consistently perform thorough inspections. For example, the universe for the sample of units that we inspected consisted of inspections passed by the Authority’s inspectors during the period April 21 to July 20, 2007, which falls within the period during which the Authority did not perform quality control inspections. Had the Authority performed routine quality control inspections, the inspectors could have identified violations that we identified during our inspections. The Authority’s Inspectors Lacked Training in the Requirements of HUD’s Housing Quality Standards The Authority contracted for inspection services, and the contracted inspectors were responsible for passing 51 of the 52 units that we inspected. There was no documentation in the contract files demonstrating that the contractors had any training in HUD’s housing quality standards. Further, the Authority did not require the inspectors to be trained in HUD’s housing quality standards at any time, nor did it provide any training to them. As a result, 35 of the 52 units that we inspected had preexisting exigent health and safety violations that the Authority’s inspectors did not identify during their inspections. The Authority Did Not Abate Failed Units as Required The Authority did not abate housing assistance payments or terminate contracts as required. We reviewed 12 units that failed inspection at least once during the period January 2006 to July 2007. For 11 of the 12 units, the Authority did not abate the housing assistance payments or terminate the contracts for the failed 13 units as required. For 1 of the 12 units, the Authority performed an initial inspection and, accordingly, had not made any housing assistance payments for the unit before it passed a later inspection. The 11 units failed inspection and remained in failed status between two to four months after the initial failed inspection, and the Authority continued to make housing assistance payments for them. Although the Authority abated $3,886 in payments for eight of the units, the abatements were not for the full amount of housing assistance payments that the Authority made while the unit was also in failed status. HUD regulations at 24 CFR 982.404(a) and (b) require the Authority to take prompt and vigorous action to enforce owner and family obligations and prohibit the Authority from making housing assistance payments for a dwelling unit that fails to meet HUD’s housing quality standards unless the owner corrects the defect within the period specified by the Authority and the Authority verifies the correction. The regulations state that owners and families have 30 calendar days (or any authority-approved extension) to make the necessary repairs for routine housing quality standards violations and 24 hours for any life-threatening violations. The Authority may terminate assistance to a family because of housing quality standards violations caused by the family. The Authority’s policy states that abatements will be effective from the day after the date of the failed inspection. Notice of abatement is generally for 30 days, depending on the nature of the repairs needed. This condition occurred because employees did not follow the Authority’s policies and procedures regarding abatements and terminations. Employees used their own discretion to continue making payments for the units. As a result, contrary to HUD regulations and its own policy, the Authority continued to pay for units that remained in failed status. The Authority made housing assistance payments totaling $9,792 and received administrative fees totaling $1,004 for units that did not meet housing quality standards. The Authority Did Not Take Timely Action to Address Violations That We Identified The Authority followed up on our inspection results and took action but did not take action in a timely manner. The Authority provided a summary schedule of the actions it took in response to the results of our inspections. The summary schedule showed that for the 37 units that failed our inspections, the Authority canceled or planned to cancel 12 housing assistance payments contracts and that it reinspected the other 25 units and gave them a passing inspection score. However, 22 of the 37 units had life-threatening violations requiring correction within 24 hours of notice, and the summary schedule did not indicate that the 14 Authority verified correction of the violations within 24 hours as required. 3 Further, for the remaining 15 units without 24-hour life-threatening violations, although the Authority’s policy requires violations to be corrected generally within 30 days, the Authority’s summary schedule did not indicate that any of the required repairs were made within that timeframe. Conclusion The Authority’s tenants 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 and abate units as required. In accordance with HUD regulations at 24 CFR 982.152(d), HUD is permitted to reduce or offset any program administrative fees paid to a public housing authority if it fails to perform its administrative responsibilities correctly or adequately, such as not enforcing HUD’s housing quality standards. The Authority disbursed $31,064 in housing assisting payments to landlords for the 35 units that materially failed to meet HUD’s housing quality standards and received $3,049 in program administrative fees for these units. In addition, the Authority did not abate units as required and disbursed $9,792 in housing assisting payments and received $1,004 in program administrative fees for 11 units that failed to meet HUD’s housing quality standards. If the Authority implements the recommendations in this report to ensure compliance with HUD’s housing quality standards, we estimate that more than $884,000 in future housing assistance payments will be spent for units that are decent, safe, and sanitary. Our methodology for this estimate is explained in the Scope and Methodology section of this audit report. Recommendations We recommend that the Director of the Office of Public Housing, Pennsylvania State Office, direct the Authority to 1A. Certify, along with the owners of the 37 units cited in this finding, that the applicable housing quality standards violations have been corrected. 1B. Reimburse its program $34,113 from nonfederal funds ($31,064 for housing assistance payments and $3,049 in associated administrative fees) for the 35 units that materially failed to meet HUD’s housing quality standards. 3 The property maintenance staff corrected life-threatening violations in three units while we performed our inspections. Although the life-threatening violations for these units were included in our overall audit results, we did not expect the Authority to follow up on these specific violations since we reported to the Authority that they had been corrected. 15 1C. Develop and implement controls to ensure that program units meet housing quality standards, thereby ensuring that $884,917 in program funds is expended only for units that are decent, safe, and sanitary. 1D. Develop and implement controls to ensure that supervisory quality control inspections are conducted and documented and that feedback is provided to inspectors to correct recurring deficiencies noted. 1E. Ensure that its inspectors are trained in the requirements of HUD’s Section 8 housing quality standards and hire inspectors who have had training in HUD’s Section 8 housing quality standards. 1F. Reimburse its program $10,796 from nonfederal funds ($9,792 for housing assistance payments and $1,004 in associated administrative fees) for the 11 units that failed to meet HUD’s housing quality standards and for which program rents were not abated in a timely manner. 1G. Develop and implement management controls to ensure that employees comply with its policies and procedures concerning abatements. 16 SCOPE AND METHODOLOGY To accomplish our objective, we reviewed • Applicable laws, regulations, the Authority’s administrative plan, HUD’s program requirements at 24 CFR [Code of Federal Regulations] Part 982, and HUD’s Housing Choice Voucher Guidebook, 7420.10G. • The Authority’s accounting records, annual audited financial statements for 2006, check register, tenant files, computerized databases including housing assistance payments, and the Authority’s board meeting minutes from 2006 and 2007. • HUD’s monitoring reports for the Authority. We also interviewed Authority employees, HUD staff, and program households. To achieve our audit objective, we relied in part on computer-processed data 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 the data to be adequate for our purposes. We statistically selected 52 of the Authority’s program units to inspect using the StatSamp template for Excel software from 227 unit inspections passed by the Authority’s inspectors during the period April 21 to July 20, 2007. The 52 units were selected to determine whether the Authority’s program units met housing quality standards. The sampling criteria used a 90 percent confidence level, 50 percent estimated error rate, and precision of plus or minus 10 percent. Our sampling results determined that 35 of 52 units (67 percent) materially failed to meet HUD’s housing quality standards. Materially failed units were those with exigent health and safety violations that predated the Authority’s previous inspections or were on the last inspection report, and the violation had not been corrected at the time of our inspection. All units were ranked, and we used auditors’ judgment to determine the material cutoff line. Based upon the sample size of 52 from a total population of 227, an estimate of 67 percent (35 units) of the sample population materially failed housing quality standards inspections. The sampling error is plus or minus 9.37 percent. There is a 90 percent confidence that the frequency of occurrence of program units’ materially failing housing quality standards inspections lays between 57.94 and 76.67 percent of the population. This equates to an occurrence of between 132 and 174 units of the 227 units in the population. We are using the most conservative numbers, which is the lower limit or 132 units. We analyzed the applicable Authority databases and estimated that the annual housing assistance payment per recipient in our sample universe was $6,704. Using the lower limit of the estimate of the number of units and the estimated annual housing assistance payment, we estimate that the Authority will spend $884,917 (132 units times $6,704 (rounded)) annually for units that are in material noncompliance with HUD’s housing quality standards. This estimate is presented 17 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. We selected a nonstatistical sample of 12 housing units for review from a universe of 895 units that failed the Authority’s housing quality standards inspection at least once during the period January 2006 to July 2007. For all 895 units, we determined the length of time between the Authority’s first inspection of the units, if available, and its reinspections that resulted in a passing score, indicating that the deficiencies had been corrected and the unit complied with HUD’s housing quality standards. We nonstatistically selected 12 units and matched the series of inspection dates for the 12 units to the Authority’s housing assistance payments register to identify payments that the Authority made for the units after the initial failed inspection. We calculated the total amount of housing assistance payments the Authority made for these units before a reinspection resulted in a passing score, if available. The Authority made housing assistance payments for only 11 of the 12 units. The Authority performed an initial inspection of one unit and had not made any housing assistance payments for the unit before it passed inspection. We performed our on-site audit work from June through December 2007 at the Authority’s main administrative office located at 351 Chestnut Street, Harrisburg, Pennsylvania, and the Authority’s Section 8 program office located at 2101 North Front Street, Building #3, Suite 101, Harrisburg, Pennsylvania. The audit covered the period January 1, 2006, through June 30, 2007, but was expanded when necessary to include other periods. We performed our audit in accordance with generally accepted government auditing standards. 18 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 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. 19 Significant Weakness Based on our audit, we believe the following item is a significant weakness: • The Authority lacked sufficient controls to ensure compliance with HUD regulations regarding unit inspections, that units met minimum housing quality standards, and abatement for units that did not meet housing quality standards. 20 APPENDIXES Appendix A SCHEDULE OF QUESTIONED COSTS AND FUNDS TO BE PUT TO BETTER USE Recommendation Funds to be put number Ineligible 1/ to better use 2/ 1B $34,113 1C $884,917 1F $10,796 Total $44,909 $884,917 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/ 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 program costs for units that are not decent, safe, and sanitary and, instead, will expend those funds for units that meet HUD’s standards. Once the Authority successfully improves its controls, this will be a recurring benefit. Our estimate reflects only the initial year of this benefit. 21 Appendix B AUDITEE COMMENTS AND OIG’S EVALUATION Ref to OIG Evaluation Auditee Comments Comment 1 22 Comment 2 Comment 3 Comment 4 23 Comment 5 Comment 6 Comment 7 Comment 8 24 Comment 9 Comment 10 Comment 11 Comment 12 Comment 13 Comment 14 Comment 15 Comment 16 Comment 17 Comment 18 Comment 19 Comment 20 25 Comment 21 Comment 22 Comment 23 26 Comment 24 Comment 25 Comment 26 Comment 27 Comment 27 Comment 29 27 Comment 28 Comment 29 28 Comment 29 Comment 30 29 Comment 31 Comment 31 Comment 32 Comment 31 30 Comment 33 Comment 31 Comment 34 Comment 31 Comment 35 Comment 31 Comment 36 31 Comment 31 Comment 37 Comment 31 Comment 38 Comment 31 Comment 39 32 Comment 31 Comment 40 Comment 31 Comment 41 Comment 13 Comment 31 Comment 42 33 Comment 31 Comment 43 Comment 31 Comment 44 34 Comment 31 Comment 45 Comment 31 Comment 46 Comment 31 35 Comment 47 Comment 31 Comment 48 Comment 31 Comment 31 Comment 49 36 Comment 31 Comment 50 Comment 31 Comment 51 Comment 31 Comment 52 37 Comment 31 Comment 53 38 Comment 31 Comment 31 Comment 54 Comment 31 Comment 55 39 Comment 31 Comment 56 Comment 31 Comment 57 Comment 31 Comment 58 40 Comment 31 Comment 59 Comment 31 Comment 60 Comment 31 Comment 61 41 Comment 31 42 OIG Evaluation of Auditee Comments Comment 1 We are encouraged by the Authority’s statements that it takes the findings very seriously and has implemented management improvements to address some of the issues included in the audit report. We commend the Authority for completing the followup actions for the 37 units that the audit determined were not in compliance with housing quality standards. Comment 2 We are encouraged by the Authority’s plans to perform the agency-wide assessment and make significant management changes that will streamline and strengthen it. Comment 3 The conclusions in the audit report are supported by audit work performed in accordance with generally accepted government auditing standards. While many of the issues were raised in the Authority’s response to the finding outline worksheets, the Authority’s comments were considered. Comment 4 We used our professional knowledge, tenant interviews, and the Authority’s latest inspection reports in determining whether a housing quality standards violation existed prior to the last passed inspection conducted by the Authority or if it was on the last passed inspection conducted by the Authority and was not corrected. During our inspections, the auditor and the HUD OIG housing inspector questioned the tenants about the violations identified during the inspections in order to determine whether the violations were preexisting or not. The HUD OIG housing inspector documented the pre-existing conditions on the inspection report and took pictures of the violations, as needed. We provided copies of all our inspection reports and the corresponding photographs to the Authority during the audit. Representatives from the Authority accompanied us on all of our inspections. The representatives intermittently made comments pertaining to violations that we identified. We considered the comments in making our determinations. Contrary to the Authority’s assertion, the testimony of the tenant is a valid method to use in determining the existence of deficiencies. For example, HUD's Housing Choice Voucher Program Guidebook, 7420.10G, section 10.9, states that for SEMAP purposes, a housing quality standards deficiency found at the time of the quality control reinspection represents a “fail” quality control inspection. When rating an individual inspector’s performance, the quality control inspector should take into account whether the failed item occurred since the previous inspector was on site. Often the tenant can describe when the deficiency occurred and will be helpful in making this determination. Further, the lack of complaints by tenants does not directly correlate to a lack of deficiencies in their homes. The tenants may have registered complaints with the landlord and not the Authority or the tenants simply may not know that deficiencies, such as those we identified during our inspections, were violations of HUD’s housing quality standards. 43 Comment 5 The Authority’s objection to the support for the finding is without merit. As indicated in the second paragraph on page three of its response, the Authority admits, by its own analysis, that 20 units could be substantiated as having preexisting conditions. Further, as stated earlier, we used our professional knowledge, tenant interviews, and the Authority’s latest inspection reports in determining whether a housing quality standards violation existed prior to the last passed inspection conducted by the Authority or if it was on the last passed inspection conducted by the Authority and was not corrected. Comment 6 The auditors did not assert that the inspector’s determination that conditions were preexisting was the sole support for concluding that a condition was preexisting. Rather, in consultation with our certified HUD inspector, we used our professional knowledge, tenant interviews, and the Authority’s latest inspection reports to determine whether a violation existed prior to the last passed inspection conducted by the Authority. In the event that we could not reasonably make that determination, we did not categorize the violation as preexisting. Comment 7 We have considered the Authority’s response and revised the final audit report as deemed appropriate. Our evaluation of the Authority’s objections to deficiencies that the audit identified in specific units is included in the comments to the Authority’s spreadsheet found on pages 30 through 42 of this report. Comment 8 We did not disregard the explanation provided and did not categorize the unit as having a preexisting condition based on the stained ceiling throughout the unit. However, the stained suspended ceiling and the leak in the bathroom were cited as preexisting conditions. These were not the only preexisting conditions cited for this unit. See Comments 13 and 42. Comment 9 In consultation with our certified HUD inspector, we used our professional knowledge, tenant interviews, and the Authority’s latest inspection reports to determine whether a violation existed prior to the last passed inspection conducted by the Authority. In the event that we could not reasonably make that determination, we did not categorize the violation as preexisting. We provided the Authority with factual descriptions of all our inspections addressed in this report. Comment 10 The determinations that flaking and chipped paint was a preexisting violation were supported by statements made by the tenants. Comment 11 The determination that a loose board on a deck was a preexisting violation was supported by statements made by the tenant. Comment 12 The tenant explained to the inspector and the auditor, in the presence of the Authority’s employees, that the second floor tenant uses the hose to fill a portable pool in the back yard and has kept it in the doorway all summer and refuses to remove it. As a result, vermin are able to enter the basement through the open doorway. 44 Comment 13 The fact that a door seal was broken is enough to determine that the refrigerator was unable to maintain the proper interior temperature. HUD's Housing Choice Voucher Program Guidebook, 7420.10G, section 10.3, states that the refrigerator must be of adequate size for the family and capable of maintaining a temperature low enough to keep food from spoiling. The guidebook includes the following example for clarification: What temperature must a refrigerator maintain to keep food from spoiling? • Above 32° F, but generally below 40° F. • Consider how often the refrigerator will be opened. Proper temperatures are difficult to maintain if the refrigerator is frequently opened during warm weather, door seals are removed or broken, or the door sits open. Comment 14 We did not cite a loose vinyl baseboard as a preexisting violation in any of the units that we inspected. Comment 15 We did not cite a defective smoke alarm as a preexisting condition in any of our inspection reports. We did cite the lack of a smoke detector in the basement, for example, as a preexisting condition. Comment 16 The determination that a hole in the drywall was a preexisting violation was supported by statements made by the tenant. Comment 17 None of the units included in the audit report were cited for having an electric cord traversing a walking area. We conducted two extra inspections to ensure that we would meet the requirements for our statistical analysis. Although the inspection for this particular unit included a violation for having an electric cord across the floor, we did not include the inspection for this unit in our audit results. We provided the inspection report to the Authority for its information. Further, anything that transverses a walking area is considered a tripping hazard and is a violation of housing quality standards. The regulations at 24 CFR 982.401(g)(2)(iv) state that the condition and equipment of interior and exterior stairs, halls, porches, walkways, etc., must not present a danger of tripping and falling. Comment 18 At no time did we enter a unit where there was not an adult present. Nowhere did we claim that a minor child provided a statement that we used as the sole justification for determining that a broken pane of glass was preexisting. Further, although the Authority stated that it “has a copy of a “move-in” inspector signed by the Landlord and the Tenant, which is attached” the document was not attached as indicated. 45 Comment 19 Deficiencies such as holes in the walls, etc., were confirmed by asking the tenant and by using professional judgment. The hole in this instance was determined to be preexisting. Further, the housing quality standards regulations at 24 CFR 982.401 (a)(3) state that all program housing must meet the housing quality standards performance requirements both at commencement of assisted occupancy, and throughout the assisted tenancy. Also, the acceptability criteria for structure and materials states that ceilings, walls, and floors must not have any serious defects such as severe bulging or leaning, large holes, loose surface materials, severe buckling, missing parts, or other serious damage. Comment 20 The determination that two inoperable stove burners were preexisting violations were supported by statements made by the tenant. We did not cite the outlet cover and loose carpet on the top risers as preexisting conditions. Comment 21 To the contrary, these examples demonstrate the efficacy of the OIG inspections upon which the conditions of the findings are based. Each of the OIG inspections were systematically documented using the HUD Inspection Checklist, Housing Choice Voucher Program, form HUD-52580. In order to meet all housing quality standards requirements, inspections must be conducted and recorded using form HUD 52580-A or 52580. In addition to documenting the results on the inspection form, we also documented the results by taking pictures as appropriate. Comment 22 We believe that the inspectors’ flat fee arrangements coupled with the lack of quality controls created weakness in the Authority’s inspection program. As a result, the inspectors may not have identified all of the violations in the units they inspected as was demonstrated by the significant number of deficiencies that we identified during our inspections of the units. The language in the contract may be standard within the industry, but the compensation should be related to the quality of the inspector’s work. Our inspection results showed the Authority’s inspectors passed 35 units during the prior four month period with a total of 233 preexisting deficiencies. These results provide the basis for the quality of the inspection work provided by the Authority’s inspectors. We revised the text in the report to clarify this point. Comment 23 We did not conclude that the Authority did not perform adequate quality control inspections; rather we concluded that the Authority did not perform quality control inspections throughout the year. Further, although the representative from the HUD Philadelphia field office informed the Authority that it could combine inspections, the 14 inspections the Authority selected were the only units that we initially passed. The Authority did not consider the other 38 inspections that we performed during the audit. Had the Authority taken all of our inspections and considered them, rather than selectively taking only the 14 inspections that we initially passed, the Authority’s quality control process would have shown that 42 of 67 (15 conducted by the Authority and 52 that we conducted) or 63 percent of the units inspected failed the quality control review process. 46 Comment 24 We disagree with the Authority’s statement that each month it conducts quality control inspections of at least one of the inspection types, selected from the previous month’s passed inspection results because, as stated in the audit report, the Authority did not conduct any quality control inspections between March 23 and July 23, 2007. Comment 25 We take no exception to these statements. We would expect the Authority to take action on complaints. Comment 26 We considered the Authority’s quality control inspection log and its complaint log for housing quality standards deficiencies. However, as stated earlier, the Authority did not conduct any quality control inspections between March 23 and July 23, 2007; the Authority did not consider the 37 inspections that we performed during the audit that resulted in a failing assessment of the unit; and we would expect the Authority to take action on complaints. However, the results of our inspections were brought to the attention of the Authority via our audit and were not detected during any quality control inspections. The audit has identified weaknesses and includes recommendations for corrective actions to address the weaknesses. Comment 27 We are encouraged by the Authority’s statements that it has taken corrective action and will continue to take corrective action to address the recommendations. The objection of the Authority to the ineligible costs is noted. However, as stated in the audit report, HUD regulations at 24 CFR [Code of Federal Regulations] 982.401 require that all program housing meet HUD’s housing quality standards at the beginning of the assisted occupancy and throughout the tenancy. HUD compensates the Authority for the cost of administering the program through administrative fees. In accordance with 24 CFR 982.152(d), HUD is permitted to reduce or offset any program administrative fees paid to a public housing authority if it fails to perform its administrative responsibilities correctly or adequately, such as not enforcing HUD’s housing quality standards. Comment 28 We did not overstate the amount of ineligible funds. We used a conservative methodology to compute the ineligible funds. As we explained at the exit conference, for the units that had preexisting violations we did not calculate any ineligible housing assistance payments for the first 30 days after the date of the Authority’s inspection. At the exit conference, the Director of HUD’s Office of Public Housing, Pennsylvania State Office, acknowledged that we were conservative in our approach. The Director acknowledged that we did not have to exclude the first 30 days from our calculations. Also, after the exit conference, we provided the Authority a copy of the spreadsheet showing our calculations. Further, the Authority stated that by its calculation, the OIG has overstated the amount of ineligible funds by at least $10,512. This figure was also shown on the first page of the attached spreadsheet. However, the amount of funds listed on the spreadsheet total $9,692 not $10,512. 47 As stated in the audit report, in accordance with HUD regulations at 24 CFR 982.152(d), HUD is permitted to reduce or offset any program administrative fees paid to a public housing authority if it fails to perform its administrative responsibilities correctly or adequately, such as not enforcing HUD’s housing quality standards. The Authority disbursed $31,064 in housing assisting payments to landlords for the 35 units that materially failed to meet HUD’s housing quality standards and received $3,049 in program administrative fees for these units. Comment 29 The Authority did not provide any evidence that it had funds in its administrative fee reserve to reimburse the ineligible amounts. If the Authority has funds in its administrative fee reserve to reimburse the ineligible amounts, then we would expect the Authority to do so, as appropriate. If not, the Authority needs to reimburse its program from nonfederal funds. Comment 30 We have included the Authority’s entire response as an appendix to the audit report. We recognize the Authority’s acknowledgement that it needs to make program improvements. The methodology supporting the conclusions in the audit report is sound and the conclusions are supported. We agree that some judgment is involved; however, as stated earlier, we used our professional knowledge, tenant interviews, and the Authority’s latest inspection reports in drawing our conclusions. Comment 31 In consultation with our certified HUD inspector, we used our professional knowledge, tenant interviews, and the Authority’s latest inspection reports to determine whether a violation existed prior to the last passed inspection conducted by the Authority. In the event that we could not reasonably make that determination, we did not categorize the violation as preexisting. Comment 32 Regarding the missing handrail on the basement stairway, HUD's Housing Choice Voucher Program Guidebook, 7420.10G, section 10.3, states that handrails are required when four or more steps (risers) are present, and protective railings are required when porches, balconies, and stoops are thirty inches off the ground. In this case, there were seven risers and the top of the steps was more than thirty inches off the ground. Comment 33 In the inspection report that we provided the Authority the inspector wrote that there was air infiltration through the door gaps. His description of the accompanying photos stated that the gaps were visible on the second floor bedroom door to the outside and that it was in need of weather stripping. The defect results in significant air infiltration into the unit. HUD's Housing Choice Voucher Program Guidebook, 7420.10G, section 10.3, states that the Authority must determine that units are free from water, excessive air, and vermin infiltration. Comment 34 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted 48 that although the Authority contested five violations, there were nine other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Comment 35 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested one violation, there were two other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Comment 36 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. When our inspector made the notation "GFCI does not trip, stays on" he determined the condition was preexisting because the GFCI was improperly wired. That is, the GFCI has two sets of contacts. One set is for the "hot" wires to be connected and the second set to connect ordinary outlets that would be protected by the same GFCI. However, if the "hot" wires are connected to the wrong screws, as was the case in the unit inspected, the GFCI stays on and does not trip. We noted that although the Authority contested five violations, there were four other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority indicated that the unit failed reinspection on November 2, 2007, and it was scheduled to terminate from the program on December 21, 2007. Comment 37 The Authority claims that air conditioners are generally not used in the spring and that an air conditioner could have been installed and removed by the tenant during the months in between our inspection and the Authority’s last inspection. The Authority also claims that the unit was painted after the Authority’s inspection, but provided no evidence to support the assertion. Comment 38 When our inspector made the notation "GFCI does not trip, stays on" he determined the condition was preexisting because the GFCI was improperly wired. That is, the GFCI has two sets of contacts. One set is for the "hot" wires to be connected and the second set to connect ordinary outlets that would be protected by the same GFCI. However, if the "hot" wires are connected to the wrong screws, as was the case in the unit inspected, the GFCI stays on and does not trip. Comment 39 The tenant explained to the inspector and the auditor, in the presence of the Authority’s employees, that the second floor tenant uses the hose to fill a portable pool in the back yard and has kept it in the doorway all summer and refuses to remove it. As a result, vermin are able to enter the basement through the open doorway. Moreover, the Authority indicated that the 24-hour deficiency was confirmed on September 6, 2007, that there was a reinspection on November 1, 2007, and the contract was cancelled on November 30, 2007. 49 Comment 40 The Authority indicated that the unit was reinspected on October 16, 2007, and the unit was scheduled for contract cancellation on December 31, 2007. Comment 41 Not only did our inspector determine that the handrail bracket was loose, but he also noted that the span between handrail brackets is too long and it needs an intermediate bracket. No intermediate brackets were noted to have been installed prior to our inspection. Also, the reversed hot/neutral outlets were determined to be preexisting because the outlets were wired incorrectly when the outlets were installed. Comment 42 See Comment 38. Also, the Authority claims that the stained ceiling and the leak in the ceiling occurred after its May 10, 2007, inspection and makes reference to work orders from the landlord. However, the Authority did not provide copies of the work orders to support its assertion and these deficiencies were still present when we inspected the unit on August 21, 2007. Also, the stained suspended ceiling was determined to be preexisting and the stained ceiling in the remainder of the unit was determined to be non-preexisting. This unit was also discussed in Comment 13 above. Comment 43 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested four violations, there were three other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Comment 44 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested six violations, there were three other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Comment 45 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested six violations, there were seven other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority indicated that the unit was reinspected on November 1, 2007, that the unit failed the reinspection, and was scheduled for contract cancellation on December 31, 2007. Comment 46 HUD's Housing Choice Voucher Program Guidebook, 7420.10G, section 10.3, states that plumbing fixtures must be free of threats to health and safety; water- heating equipment must be installed safely and must not present any safety hazards; and all water heaters must have temperature/pressure relief valves, and a discharge line. Program regulations set forth basic housing quality standards which all units must meet before assistance can be paid for a unit. Housing quality standards establish the minimum criteria necessary for the health and 50 safety of program participants. In this instance, (see photo on page 10 of this report) the condition presented a health and safety issue for the tenant. Comment 47 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested five violations, there was one other preexisting violation that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Comment 48 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested two violations, there were two other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority indicated that the unit was reinspected on November 8, 2007, that the unit failed the reinspection, and was scheduled for contract cancellation on December 31, 2007. Comment 49 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested four violations, there were six other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority indicated that the unit was reinspected on November 2, 2007, that the unit failed the reinspection, and the contract was cancelled on December 31, 2007. Comment 50 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested two violations, there was one other preexisting violation that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority commented that “without specific details of the actual condition, it is hard to determine if indeed this particular installation was not in compliance with article 406 of the National Electrical Code.” However, the Authority reported that it reinspected and passed the unit on November 9, 2007. The Authority’s inspector should have been able to provide the specific details to determine compliance with the code. Comment 51 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested nine violations, there were three other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Comment 52 HUD's Housing Choice Voucher Program Guidebook, 7420.10G, section 10.3, states that plumbing fixtures must be free of threats to health and safety; water- 51 heating equipment must be installed safely and must not present any safety hazards; and all water heaters must have temperature/pressure relief valves, and a discharge line. Program regulations set forth basic housing quality standards which all units must meet before assistance can be paid for a unit. Housing quality standards establish the minimum criteria necessary for the health and safety of program participants. In this instance, the condition presented a health and safety issue for the tenant. Comment 53 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested nine violations, there were four other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority commented that “without specific details of the actual condition, it is hard to determine if indeed this particular installation was not in compliance with article 406 of the National Electrical Code.” However, the Authority reported that it reinspected and passed the unit on November 2, 2007. The Authority’s inspector should have been able to provide the specific details to determine compliance with the code. Comment 54 The Authority commented that “without specific details of the actual condition, it is hard to determine if indeed this particular installation was not in compliance with article 406 of the National Electrical Code.” However, the Authority reported that it reinspected and passed the unit on November 1, 2007. The Authority’s inspector should have been able to provide the specific details to determine compliance with the code. Comment 55 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested six violations, there were five other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Comment 56 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested three violations, there were two other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority commented that “without specific details of the actual condition, it is hard to determine if indeed this particular installation was not in compliance with article 406 of the National Electrical Code.” However, the Authority reported that it reinspected and passed the unit on November 28, 2007. The Authority’s inspector should have been able to provide the specific details to determine compliance with the code. Comment 57 The Authority’s quality standards for its Section 8 existing housing program state that a bedroom shall not be less than 100-square feet of floor space and shall not 52 be less than 8 feet in any dimension. Moreover, the Authority indicated that the unit was disqualified for being too small and that the tenant transferred to an eligible unit. Comment 58 The Authority commented that “without specific details of the actual condition, it is hard to determine if indeed this particular installation was not in compliance with article 406 of the National Electrical Code.” However, the Authority reported that it reinspected and passed the unit on November 1, 2007. The Authority’s inspector should have been able to provide the specific details to determine compliance with the code. Comment 59 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested four violations, there were sixteen other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority indicated that the contract was cancelled due to tenant-caused housing quality standards deficiency – no UGI natural gas service. Comment 60 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested three violations, there were four other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority indicated that the 24-hour deficiencies were corrected and a cancellation letter was mailed on September 21, 2007, due to the unacceptable unit location. Comment 61 We disagree with the Authority’s contention. The violations cited were preexisting for reasons previously explained with similar violations. We noted that although the Authority contested seven violations, there were three other preexisting violations that the Authority did not contest. Moreover, the Authority did not contest any of the ineligible costs that we reported for this unit. Further, the Authority indicated that the unit was reinspected on November 1, 2007, that the unit failed the reinspection, and was scheduled to be terminated on December 31, 2007. 53
The Harrisburg Housing Authority, Harrisburg, Pennsylvania, Did Not Ensure That Its Section 8 Housing Choice Voucher Program Units Met Housing Quality Standards
Published by the Department of Housing and Urban Development, Office of Inspector General on 2008-04-15.
Below is a raw (and likely hideous) rendition of the original report. (PDF)