Issue Date
December 18, 2009
Audit Report Number
2010-FW-1001
TO: Justin Ormsby, Director, Office of Public Housing, 6APH
//signed//
FROM: Gerald R. Kirkland
Regional Inspector General for Audit, Fort Worth Region, 6AGA
SUBJECT: Dallas Housing Authority, Dallas, Texas, Demonstrated Capacity to Administer
Its Recovery Act Capital Fund Formula Grant
HIGHLIGHTS
What We Audited and Why
As part of the Office of the Inspector General’s (OIG) directive to determine
whether safeguards exist to ensure that American Recovery and Reinvestment Act
of 2009 (Recovery Act) funds are used for their intended purposes, we audited the
Dallas Housing Authority’s (Authority) Recovery Act Public Housing Capital
Fund formula grant (grant). We selected the Authority based upon a risk
assessment of regional housing authorities that were allocated capital funds under
the Recovery Act. Our objective was to evaluate the Authority’s capacity in the
areas of internal controls, eligibility, financial controls, procurement, and
output/outcomes in administering its grant.
What We Found
Overall, the Authority demonstrated capacity to administer its grant in accordance
with requirements. It had sufficient controls in place to ensure activities were
properly procured, funds were obligated and expended within the time allotted,
and payments were properly authorized. The Authority’s Recovery Act initiatives
were well underway and appeared to include eligible activities consistent with its
grant agreement. However, the Authority should address the issues identified in
this report to help ensure it fully expends its grant funds on eligible activities
within Recovery Act deadlines.
What We Recommend
We recommend that the Director, U. S. Department of Housing and Urban
Development (HUD), Office of Public and Indian Housing, Fort Worth, Texas,
work with the Authority to resolve documentation requirements for administration
and management improvements expense categories. We also recommend that
HUD require the Authority to revise its budget and reallocate $280,000 in
budgeted funds to other eligible activities. Further, HUD should require the
Authority to properly reclassify $27,425 in costs associated with bid advertising
and duplicating bid specifications, require a contractor to correct improperly
installed garage doors, and enforce lease provisions that hold tenants accountable
for damages.
We agree with HUD’s management decisions for all of the recommendations.
Further, we agree that final action is complete for recommendations 1A, 1B, and
1C. We will make the appropriate entries in the departmental audit resolution
tracking system upon issuance of the report.
For each recommendation without a completed final action, 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 our draft report to the Authority on December 2, 2009, and
discussed it with Authority officials at the exit conference on December 7, 2009.
The Authority provided its written comments to our draft report on December 14,
2009. The Authority agreed with the finding and recommendations and provided
information about how it implemented or will implement the recommendations.
The complete text of the auditee’s response, along with our evaluation of that
response, can be found in appendix B of this report.
2
TABLE OF CONTENTS
Background and Objective 4
Results of Audit
Finding: The Authority Demonstrated Capacity to Administer the Grant in 5
Accordance with Requirements
Scope and Methodology 10
Internal Controls 12
Appendixes
A. Schedule of Questioned Costs and Funds To Be Put to Better Use 13
B. Auditee Comments and OIG’s Evaluation 14
3
BACKGROUND AND OBJECTIVE
In 1938, the Dallas City Council established the Dallas Housing Authority (Authority). A
five-member board of commissioners1 governs the Authority. The board appoints a president and
chief executive officer to administer the operations of the Authority. The Authority’s main office is
located at 3939 North Hampton Road, Dallas, Texas.
The Authority receives capital funds annually via a formula grant from the U. S. Department of
Housing and Urban Development (HUD). The Authority may use its capital funds for
development, financing, modernization, and management improvements. It received $6.9 and
$6.4 million in capital fund grants in 2008 and 2009, respectively.
On February 17, 2009, the President signed the American Recovery and Reinvestment Act of
2009 (Recovery Act). Title XII of the Recovery Act appropriated $4 billion to carry out capital
and management activities for public housing agencies.2 By formula, HUD allocated $8.8
million to the Authority for its capital and management activities and executed a Recovery Act
Public Housing Capital Fund formula grant (grant) agreement, effective March 18, 2009.
Transparency and accountability were critical priorities in the funding and implementation of the
Recovery Act. The Recovery Act imposed additional reporting requirements beyond the
standard reporting requirements for the Authority’s capital fund grants. In addition, the
Authority must obligate 100 percent of its Recovery Act grant by March 17, 2010. At that date,
any unobligated funds must be recaptured by HUD.
Our objective was to evaluate the Authority’s capacity in the areas of internal controls,
eligibility, financial controls, procurement, and output/outcomes in administering its grant.
1
The mayor of Dallas appoints board members.
2
As authorized under Section 9 of the United States Housing Act of 1937.
4
RESULTS OF AUDIT
Finding: The Authority Demonstrated Capacity to Administer the Grant
in Accordance with Requirements
The Authority had sufficient controls in place to ensure activities were properly procured, funds
were obligated and expended within the time allotted, and payments were properly authorized.
However, the Authority needs to revise its grant budget to reallocate costs for activities it no
longer plans to charge to the grant. In addition, it incorrectly classified certain expenses and did
not ensure that a contractor properly installed deliverables. By addressing the issues identified in
this report, the Authority could strengthen its capacity and achieve additional program goals.
The Authority Had Sufficient
Controls
The Authority’s development department was responsible for ensuring the Authority
obligated and expended grant funds within the established time limits. The director
of development tracked Recovery Act grant obligations, expenditures, and contracts
using Excel spreadsheets and met periodically with finance staff to compare them to
information in the Authority’s financial system. While not a flawless method, it
appeared to meet the Authority’s needs.
The Authority’s finance department continued to experience challenges; however, it
appeared to be constructively addressing them. Despite its challenges, the finance
department had sufficient controls in place to properly record obligations and
expenditures in its accounting system and report the information to HUD.
HUD's financial system (electronic Line of Credit Control System (eLOCCS)) and
the Authority’s internal records showed the following for the Authority’s $8.8
million grant:
Total Percentage Total Percentage
obligated obligated expended expended
eLOCCS report
as of $3,271,841 37.12 $819,822 9.30
September 30, 2009
Authority records
as of $6,256,530 70.97 $1,046,894 11.88
September 28, 2009
Table 1: It appeared the Authority’s development department updated its records after its September 28,
2009, board meeting, but its finance department had not yet obligated the funds in eLOCCS (the Authority
could not obligate grant funds in eLOCCS until the contracts were executed).
5
While the Authority had made progress in obligating and expending its grant
funds, it had not drawn down any of the $880,000 budgeted for administration.3
The Authority had not drawn down administrative funds because it did not have
documentation of specific administrative expenses associated with the grant, as
required by HUD. Specifically, HUD required the Authority to provide
supporting documentation for drawdown requests for administration and
management improvements for its Recovery Act grant in anticipation of guidance
from the Office of Management and Budget regarding transparency reporting
requirements. Although the Authority had incurred administrative costs
associated with the grant, it did not allocate them to the grant in its records.
Under the standard capital fund program, it was not required to do so;4 therefore,
it did not have detailed information available to support drawdowns for
administration. If the Authority is unable to adequately support its administrative
expenses in a timely manner, the budgeted $880,000 would be subject to
recapture. Following issuance of the draft audit report, HUD worked with the
Authority to resolve documentation requirements for these expense categories.
Authority management was responsive to issues raised during the review and took
appropriate action when warranted. The Authority should continue to strive for
good coordination between the development and finance departments to ensure its
records reconcile. The Recovery Act requirement to expedite obligation and
expenditure of grant funds makes this need more urgent than normal.
The Authority Should Revise Its
Grant Budget
Because of the shorter timeframes for obligating and expending Recovery Act
funds, the Authority must make timely revisions to its budgets and activities to
ensure it continues to maximize its use of these funds. For example, the
Authority’s Recovery Act procurements recognized aggressive bidding, and the
Authority planned to reallocate the resultant cost savings to additional activities.
As a result of the audit, the Authority revised its grant budget to reflect the
additional activities it planned to undertake with its cost savings and addressed the
issues identified below.
The Authority allocated $180,000 in its grant budget for a physical needs
assessment required by its grant agreement with HUD. However, as of September
30, 2009, HUD had not provided guidance on performing the assessment.
Instead, HUD advised5 public housing agencies not to budget any Recovery Act
funds for physical needs assessments. To avoid recapture, the Authority
3
As of September 30, 2009.
4
Under asset management, fees that the central office cost center earned were “de-federalized,” thus the
Authority did not and was not required to allocate central office expenditures to specific grants.
5
July 24, 2009, Frequently Asked Questions on HUD’s Office of Capital Improvements Web site.
6
implemented the recommendation to reallocate this $180,000 to other eligible
activities before the March 17, 2010, obligation deadline.
In another instance, the Authority allocated $100,000 to remodel space in its
community and support services department. It expended $43,792 on the project
before deciding not to charge the cost to the grant. The Authority revised its
budget to reallocate the $100,000 for this project to other eligible activities and
obligate the funds accordingly.
The Authority misclassified $15,757 in bid advertising expenses and $11,668 in
costs for reproducing bid specification documents. This error occurred because
the Authority incorrectly budgeted $30,000 in bid advertising costs to
management improvements rather than administration. In addition, HUD
required costs for reproducing bid specification documents to be charged to
planning, not management improvements.6 The Authority revised its budget to
reclassify bid advertising expenses as administration7 and add a line item for
planning to include the costs of reproducing bid specifications. The Authority
should also reclassify the costs in its financial records and eLOCCS.
The Authority Should Hold the
Contractor Responsible and
Enforce Lease Provisions
The Authority executed a $27,000 contract to replace 50 garage doors for single-
family homes in its Lakewest Village scattered site. After only 8 years,8 all
garage doors at the site were replaced. Work under the contract included
furnishing and installing all materials, supplies, equipment, and labor to complete
the garage door replacements. However, some of the doors appeared to have been
improperly installed, and the contractor failed to replace some of the rotted wood
surrounding the doors as required by the contract. The contract required the
contractor to guarantee materials and workmanship for 1 year. The Authority
agreed to implement the recommendation to require the contractor to adjust doors
that did not appear to have been properly installed and replace rotted trim as
required in the scope of work.
6
HUD’s Low-Rent Accounting Technical Guide prescribes the uniform chart of accounts that the Authority must
use. This requirement allowed HUD to review and evaluate budget proposals for compliance with regulatory
requirements and to monitor actual expenditures against approved budget estimates.
7
In doing this, the Authority should be cognizant of the 10 percent limitation on administration.
8
Lakewest Village was built in 2001.
7
Figure 1: The garage door had a gap between the door and the right side trim. Minor damage was noted on
the top right side of the bottom panel. The trim on the left side appears to be rotted.
In addition, within 4 months of replacement, several garage doors showed visible
damage. The Authority should enforce provisions of its lease that hold tenants
accountable for damages to the doors. Authority management agreed to require
tenants to pay actual costs for repairing the damages. Had management enforced
the lease provisions, it may not have needed to replace all 50 garage doors after
only 8 years in service. Managing the properties in accordance with the lease
should mitigate future costs and prolong the useful life of the garage doors.
Figure 2: These garage doors appear to have been properly installed; however, they have been damaged.
Conclusion
Despite ongoing challenges in its finance department, the Authority demonstrated
the capacity to administer the grant in accordance with requirements. It had
sufficient controls in place to ensure activities were properly procured, funds were
obligated and expended within the time allotted, and payments were properly
authorized. The Authority addressed the budgetary issues identified in this report
to help ensure it fully expends its grant funds on eligible activities within the
8
Recovery Act deadlines. It should take expedient action to address the remaining
concerns related to the correct classification of costs in its financial records and
eLOCCS as well as enforcing contract and lease provisions associated with the
garage doors at Lakewest Village.
Recommendations
We recommend the Director, Office of Public and Indian Housing, Fort Worth,
Texas, require the Authority to
1A. Work with HUD to resolve documentation requirements for administration
and management improvements expense categories in its budget, including the
$880,000 the Authority budgeted for administration, or reprogram the funds to
other eligible activities.
1B. Revise its budget to reallocate $180,000 budgeted for a physical needs
assessment to other eligible activities.
1C. Revise its budget to reallocate $100,000 budgeted for remodeling the
community and support services space to other eligible activities.
1D. Revise its budget to properly reclassify $30,000 in bid advertising costs as
administration and properly reclassify $15,757 expended for bid advertising in
its financial records and eLOCCS.
1E. Revise its budget to include a line item in planning for the cost of duplicating
bid specifications, including at least the $11,668 already expended, and to
reclassify the expenses in its financial records and eLOCCS.
1F. Require the contractor to correct improperly installed garage doors at
Lakewest Village.
1G. Enforce lease provisions at Lakewest Village that hold tenants accountable
for damages.
9
SCOPE AND METHODOLOGY
We performed the audit at Authority's main offices at 3939 North Hampton Road, Dallas, Texas,
and at our offices in Fort Worth, Texas, from August 6 through September 30, 2009. The scope
of the audit was February through August 2009. We expanded the scope to include funding
obligations and expenditures reported to HUD as of September 30, 2009. We initially planned to
assess the Authority’s capacity to administer the grant by reviewing its performance for activities
that were similar to those it planned to undertake with its Recovery Act grant. However, the
review expanded beyond assessing the Authority’s capacity because the Authority had made
substantial progress in obligating Recovery Act funds. This allowed us to perform testing of
actual Recovery Act procurements and outputs/outcomes of in-progress and completed Recovery
Act projects.
To achieve our audit objectives, we
Obtained and reviewed relevant laws, regulations, program guidance, and grant
agreements.
Interviewed HUD and Authority staff.
Obtained, analyzed, and reviewed electronic financial records.
Reviewed supporting documentation for disbursements.
Reconciled recorded transactions with grant drawdown requests.
Reviewed procurement activities.
Inspected deliverables.
We performed a data reliability assessment of the Authority’s detailed general ledger trial
balance as of August 31, 2009. We used financial data from the Authority’s accounting system
to identify a universe of transactions from which to select sample items for testing. We based
audit conclusions on the results of tests performed on the selected sample, not on the financial
data. We tested the data by tracing it to source documentation while performing sample testing.
We did not identify any discrepancies between the data and the sample items. We also
performed limited analytical testing of general ledger entries and compared the expenses
recorded in the general ledger with the records maintained by the Authority’s development
department. Based on the planned use of the data, the minimal risk associated with using the
data, and the review of corroborating evidence, the data were complete and sufficiently reliable
to meet the stated audit objective.
We used ACL software to identify a sampling universe and select a random sample of
transactions in the general ledger trial balance as of August 31, 2009. After excluding certain
administrative expenditures that were subject to HUD mandatory review, we summarized the
transactions to identify a sampling universe of 52 journal entries. Further review and
classification of the data showed one payee accounted for 33 journal entries (63percent) but only
$11,668 of the $464,803 expended (2.5 percent). To prevent skewing the sampling results, we
selected one sample journal entry from that payee and five from the remaining payees, resulting
in a sample of more than 10 percent of the journal entries. Because we selected the journal
entries randomly, we expect the sample to be representative of the Authority's performance for
10
nonadministrative expenditures under the grant. We did not project the sampling results to the
audit universe. The questioned costs reported are for specific sample items only.
We conducted the audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.
11
INTERNAL CONTROLS
Internal control is an integral component of an organization’s management that provides
reasonable assurance that the following controls are achieved:
Program operations,
Relevance and reliability of information,
Compliance with applicable laws and regulations, and
Safeguarding of assets and resources.
Internal controls relate to management’s plans, methods, and procedures used to meet its
mission, goals, and objectives. They include the processes and procedures for planning,
organizing, directing, and controlling program operations as well as the systems for measuring,
reporting, and monitoring program performance.
Relevant Internal Controls
We determined that the following internal controls were relevant to our audit
objective:
Program operations – Policies and procedures that management implemented
to reasonably ensure that its program met its objectives.
Validity and reliability of data – Policies and procedures that management
implemented to reasonably ensure that valid and reliable data were obtained,
maintained, and fairly disclosed in reports.
Compliance with laws and regulations – Policies and procedures that
management implemented to reasonably ensure that its resource use was
consistent with laws and regulations.
Safeguarding resources – Policies and procedures that management
implemented to reasonably ensure that its resources were safeguarded against
waste, loss, and misuse.
We assessed the relevant controls identified above. A significant weakness exists if
management controls do not provide reasonable assurance that the process for
planning, organizing, directing, and controlling program operations will meet the
organization’s objectives.
Significant Weaknesses
Based on our review, we did not identify any significant weaknesses.
12
APPENDIXES
Appendix A
SCHEDULE OF QUESTIONED COSTS
AND FUNDS TO BE PUT TO BETTER USE
Recommendation Unsupported 1/ Funds to be put to
number better use 2/
1A $880,000
1B 180,000
1C 100,000
1D9 $15,757 14,243
1E 11,668
Totals $27,425 $1,174,243
1/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program or activity when we
cannot determine eligibility at the time of the audit. Unsupported costs require a decision by HUD program
officials. This decision, in addition to obtaining supporting documentation, might involve a legal interpretation
or clarification of departmental policies and procedures.
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. These amounts include reductions in
outlays, deobligation of funds, withdrawal of interest, costs not incurred by implementing recommended
improvements, avoidance of unnecessary expenditures noted in preaward reviews, and any other savings that
are specifically identified. In this case, it represents funds that can be properly classified, obligated, and
expended within the time required that would otherwise be at risk of recapture.
9
The Authority should revise its budget to properly reclassify $30,000 in bid advertising costs as administration
costs. To avoid double counting, we split the amount between unsupported and funds to be put to better use
($15,757 + $14,243 = $30,000).
13
Appendix B
AUDITEE COMMENTS AND OIG’S EVALUATION
Ref to OIG Evaluation Auditee Comments
Dallas Housing Authority
December 14, 2009
Mr. Gerald R. Kirkland, Regional Inspector General for Audit
Office of Inspector General
U.S. Department of Housing & Urban Development
819 Taylor Street, Room 13A09
Fritz Lanham Federal Building
Fort Worth, Texas 76102
Subject: Dallas Housing Authority, Dallas, Texas Demonstrated Capacity to Administer
Recovery Act Capital Funds Formula Grant
Dear Mr. Kirkland:
In March 2009, the Dallas Housing Authority (DHA) received $8.8 million dollars pursuant to Title XII
of the American Recovery and Reinvestment Act of 2009 (Recovery Act) for capital and management
activities and executed a Recovery Act Public Housing Capital Fund formula grant (grant) agreement.
From August 6, 2009 to September 30, 2009, the U.S. Department of Housing and Urban Development
(HUD), Office of Inspector General (OIG) conducted an audit of the capacity of DHA to administer the
Comment 1 grant. Due to the substantial progress made by DHA in obligating the funds, the OIG elected to expand
the scope of the audit to include complete testing of actual Recovery Act procurements and
outputs/outcomes in-progress and completed Recovery Act projects.
DHA is pleased to receive the OIG’s finding that DHA demonstrated the capacity to administer the grant
in accordance with the grant requirements. DHA greatly appreciates the opportunity to meet with you,
the auditors, and Carrie E. Dobbins, Director, Technical Division, at the exit conference on the finding
and on the recommendations made. We take this opportunity to comment on the recommendations and to
apprise you of the resulting corrective actions taken.
The recommendations included (1) working with HUD to resolve documentation requirements for
administration and management improvement expense categories in the DHA budget, including the
amount of $880,000 budgeted for administration, or reprogram the funds to other eligible activities; (2)
revising the DHA budget to reallocate, reclassify, or reprogram expenses associated with a physical
needs assessment, remodeling the community and supportive services space, and bid advertising costs,
and to include a line item in planning for the cost of bid specifications; (3) contractor responsibility
relating to deficiencies in installation of garage doors at the Lakewest Village scattered site property;
and (4) lease enforcement at the Lakewest Village scattered site property for damages to garage doors.
14
On November 30, 2009, a team of HUD personnel from the Fort Worth Field Office, led by
David Storms, Facilities Management Specialist, conducted an on-site review of DHA’s
ARRA activities to date. The review covered DHA's Procurement activities and Environment
Review documentation relating to the grant. DHA's Development and Finance Departments
Comment 2 will work with this team to provide documentation to support the portion of $880,000 in
Comment 3 administrative expenditures previously requested by DHA, as HUD’s guidance has changed.
As recognized by your team, DHA was unaccustomed to providing documentation for
administrative expenditures under current HUD requirements for asset-based management, as
fees earned by the Central Office Cost Center were declared by HUD to be “de-federalized.”
DHA is pleased to report that it has met the documentation requirements prescribed. For
Comment 2 future expenses, DHA intends to adopt the procedural recommendations made by HUD of
applying a 10% administrative BLI draw request of every ARRA fund expended and drawn
down from eLOCCS.
Initially, public housing authorities (PHAs) receiving the ARRA funds were required to
Comment 4 allocate funds in their Recovery Act budgets a certain sum for a physical needs assessment.
DHA allocated $180,000 for this purpose. Later, HUD advised the recipient PHAs not to
budget any funds for such assessment. DHA has revised its budget to reflect reallocation of
Comment 5 expenses associated with the assessment. The revised budget also reflects the reallocation of
costs associated with the bid advertising and bid specifications activities referenced in #2
above. Enclosed please find a copy of the revised budget, made only to reclassify or
reprogram funds to other eligible activities.
In 2009, DHA made an administrative decision to replace the garage doors for the 50 single-
family homes in its Lakewest Village scattered site property, which was constructed in 2001.
The purpose was both a preventive-maintenance and a cost-savings strategy. By replacing all
the doors under one contract, the warranty of parts and materials run concurrent.
Additionally, DHA realized a cost savings by replacing all of the doors at one time, instead
of a piece-meal approach. While the garage doors functioned properly, there were some
deficiencies in the installation by the qualified contractor of the new doors. The Development
Comment 6 Department has contacted the responsible contractor under the warranty to correct the
deficiencies, primarily through the adjustment of spring settings as well as caulking and
replacement of some wood fittings. Many of these deficiencies require only minor
adjustments. All deficiencies/adjustments have been completed. See photographs enclosed.
For damages to the newly-installed garage doors caused by residents, DHA intends to seek
Comment 7 full repayment as provided in the lease agreements. Once the adjustments have been
completed, DHA will invoice the residents accordingly.
15
At the time of the audit, DHA records show that DHA had obligated 70.97% of the grant, while HUD’s
financial system, eLOCCS, shows only 37.12%. DHA's Development Department, as the department
responsible for ensuring that DHA obligated and expended the grant funds within the established time
limits, is working with its Finance Department to update eLOCCS to reflect the percentage (70.97%)
actually obligated.
As acknowledged, DHA has made substantial progress in obligating the grant funds, and DHA is
confident that it will be able to obligate 100% of funds within the one-year time limit, to expend 60% of
the funds within the two-year time limit, and to expend 100% of the funds within three-year time limit.
We appreciate the cooperative and forthcoming approach of everyone involved and, as always, thank you
for the assistance and guidance provided by you and your staff.
Sincerely,
MaryAnn Russ,
President & CEO,
Dallas Housing Authority
Enclosures
16
OIG Evaluation of Auditee Comments
Comment 1 OIG did not test all of the Authority's Recovery Act activities. As explained in
the scope and methodology section, we tested a sample of six transactions and the
related procurement activities. The conclusions in the report are based in part on
the sample.
Comment 2 We appreciate the efforts made by HUD and the Authority to implement the
recommendation.
Comment 3 The report noted that HUD's documentation requirements for the Recovery Act
grant differed from the standard Capital Fund program because of the associated
accountability and transparency requirements. HUD did not change its guidance
for the standard Capital Fund program.
Comment 4 HUD did not require public housing agencies to allocate Recovery Act funds for
physical needs assessments. PHAs were allowed to use regular Capital Funds for
this purpose.10
Comment 5 We commend the Authority for revising its budget to help ensure it obligates the
entire grant by the deadline. We encourage it to make the appropriate corrections
in its financial records and eLOCCS.
Comment 6 We appreciate Authority's action to ensure the contractor corrects the deficiencies.
Comment 7 We acknowledge the Authority's efforts to implement the recommendation and
encourage it to seek repayment from tenants.
10
Annual contributions contract amendment, section 7(k), and PIH notice 2009-12.
17
Dallas Housing Authority, Dallas, Texas, Demonstrated Capacity to Administer Its Recovery Act Capital Fund Formula Grant
Published by the Department of Housing and Urban Development, Office of Inspector General on 2009-12-18.
Below is a raw (and likely hideous) rendition of the original report. (PDF)