OFFICE OF AUDIT
REGION 5
CHICAGO, IL
Flint Housing Commission
Flint, MI
American Recovery and Reinvestment Act Public
Housing Capital Fund Formula Grant
2013-CH-1009 SEPTEMBER 27, 2013
Issue Date: September 27, 2013
Audit Report Number: 2013-CH-1009
TO: Willie C. Garrett, Director of Public Housing, 5FPH
//signed//
FROM: Kelly Anderson, Regional Inspector General for Audit, Chicago Region, 5AGA
SUBJECT: The Flint Housing Commission, Flint, MI, Did Not Always Administer Its Grant
in Accordance With Recovery Act, HUD’s, and Its Own Requirements
Attached is the U.S. Department of Housing and Urban Development (HUD), Office of
Inspector General’s (OIG) final audit report on the Flint Housing Commission’s American
Recovery and Reinvestment Act Public Housing Capital Fund formula grant.
HUD Handbook 2000.06, REV-4, sets specific timeframes for management decisions on
recommended corrective actions. For each recommendation without a management decision,
please respond and provide status reports in accordance with the HUD Handbook. Please furnish
us copies of any correspondence or directives issued because of the audit.
The Inspector General Act, Title 5 United States Code, section 8M, requires that OIG post its
publicly available reports on the OIG Web site. Accordingly, this report will be posted at
http://www.hudoig.gov.
If you have any questions or comments about this report, please do not hesitate to call me at
(312) 353-7832.
September 27, 2013
The Flint Housing Commission, Flint, MI, Did Not
Always Administer Its Grant in Accordance With
Recovery Act, HUD’s, and Its Own Requirements
Highlights
Audit Report 2013-CH-1009
What We Audited and Why What We Found
We audited the Flint Housing The Commission did not always comply with the
Commission’s American Recovery and Recovery Act, HUD’s, and its own procurement
Reinvestment Act of 2009 Public requirements. Specifically, it did not adequately
Housing Capital Fund formula grant support the cost reasonableness of its architectural
based upon our analysis of risk factors services’ contracts and Recovery Act funded projects.
relating to the housing agencies in As a result, HUD and the Commission lacked
Region 5’s1 jurisdiction. Our objective assurance that more than $960,000 in Recovery Act
was to determine whether the formula grant funds was used appropriately.
Commission administered its grant in
accordance with Recovery Act, the U.S. Also, the Commission did not always follow HUD’s
Department of Housing and Urban and its own contract management requirements for its
Development’s (HUD), and its own Recovery Act Capital Fund formula grant.
requirements. This is the second of twoSpecifically, it did not (1) issue payments to its
audit reports on the Commission’s contractor in accordance with HUD’s requirements for
Recovery Act grants. one project, (2) adequately manage its force account
labor unit renovations project, and (3) ensure that its
own employees were paid the appropriate Federal
What We Recommend
labor standard wage rates as required by the Davis-
Bacon Act. As a result, HUD and the Commission
We recommend that HUD require the lacked assurance that Recovery Act formula grant
Commission to (1) provide sufficient funds were used appropriately. Further, the
documentation or reimburse HUD more Commission underpaid employees nearly $22,000.
than $960,000 for the unsupported cost
estimates, wages, and materials and
supplies and (2) reimburse its
employees nearly $22,000 for Federal
labor standard wage rates not paid.
1
Region 5 includes the States of Illinois,
Indiana, Michigan, Minnesota, Ohio, and
Wisconsin.
TABLE OF CONTENTS
Background and Objective 3
Results of Audit
Finding 1: The Commission Did Not Always Comply With the Recovery Act,
HUD’s, and Its Own Procurement Requirements 5
Finding 2: The Commission Did Not Always Comply With HUD’s and Its
Own Contract Management Requirements 9
Scope and Methodology 14
Internal Controls 16
Appendixes
A. Schedule of Questioned Costs and Funds To Be Put to Better Use 18
B. Auditee Comments and OIG’s Evaluation 19
C. Federal and the Commission’s Requirements 24
2
BACKGROUND AND OBJECTIVE
The Flint Housing Commission operates a public housing program that consists of 10 low-
income housing communities with 1,248 units including 133 scattered sites throughout Flint, MI.
The following seven housing communities received American Recovery and Reinvestment Act
of 2009 formula grant funds: Richert Manor, Mince Manor, Howard Estates, Aldridge Place,
River Park, Atherton East, and scattered site homes. Richert Manor is a 132-unit single-room
high-rise building. Mince Manor is a 110-unit complex for the elderly. Howard Estates is a
family site that consists of 96 townhomes. Aldridge Place is a family site that consists of 97-
townhomes. River Park is a family site that consists of 173 townhomes. Atherton East is a
family site that consists of 192 units.
The Commission was established by the City of Flint, MI, on July 27, 1964. The Commission’s
primary funding source is the U.S. Department of Housing and Urban Development (HUD)
under the regulation of the State of Michigan’s Act 18 of 1933, MCL 125.651-709e. A five-
member board of commissioners is appointed by the mayor of Flint to serve a 5-year term. The
executive director, appointed by the board, is responsible for general supervision over the
administration of the Commission’s business and is charged with the management of its housing
projects. The Commission administers the projects under its annual contributions contract with
HUD.
On February 17, 2009, the President signed the American Recovery and Reinvestment Act. The
Recovery Act provided an additional $4 billion to public housing agencies to carry out capital and
management activities, including the modernization and development of public housing. The
Recovery Act required that $3 billion of these funds be distributed as formula grants and the
remaining $1 billion be distributed through a competitive process. In March 2009, the Commission
received a formula grant of more than $2.5 million.
According to the Recovery Act, the Commission was required to obligate 100 percent of its formula
grant funds within 1 year, expend 60 percent of the funds within 2 years, and fully expend the funds
within 3 years. The Commission had obligated 100 percent of its formula grant funds by March 17,
2010 and had spent 100 percent of its formula grant funds by March 17, 2012.
The Commission used its Recovery Act formula grant funds to procure two architectural and
engineering agreements totaling $238,127 and conduct the following 18 projects totaling more
than $2.3 million in Recovery Act grant funds.
3
Contract
Count Development Project amount
1 Aldridge Place Drainage improvements $300,273
2 Repair or replacement of
Scattered sites fencing 28,475
3 Scattered sites Basement waterproofing 31,750
4 Repair of sidewalks or entry
Mince Manor drives 40,260
5 Repair or replacement of
Howard Estates porches, sidewalks, or steps 40,721
6 Repair or replacement of
Atherton East porches, sidewalks, or steps 147,000
7 Repair or replacement of
Aldridge Place porches, sidewalks, or steps 80,699
8 Howard Estates Bathroom floor replacement 45,239
9 Aldridge Place Kitchen floor replacement 46,938
10 Howard Estates Repair of parking lots 70,000
11 Repair or replacement of
Mince Manor parking lot 173,500
12 Repair or replacement of
Atherton East parking lots 285,500
13 Richert Manor Replacement of parking lot 190,717
14 River Park Repair of parking lot 198,248
15 Richert Manor Exterior painting 96,025
16 Howard Estates Exterior renovations 294,027
17 Force account
labor Unit renovations 250,000
18 Richert Manor Lobby floor replacement $8,506
Total $2,327,878
For the fiscal years ending June 30, 2008 and June 30, 2009, HUD designated the Commission
as substandard physical based on poor physical inspection reports. Since this designation
classified the Commission as a troubled public housing agency, execution of the Recovery Act
annual contributions contract amendments was the Commission’s agreement to additional
monitoring and oversight by HUD as deemed necessary in order to ensure proper use of the
Recovery Act capital funds. The Commission was notified of HUD’s minimum baseline strategy
of monitoring and oversight, which included a manual review of all of its Recovery Act Capital
Fund grants.
Our objective was to determine whether the Commission administered its Recovery Act formula
grant in accordance with HUD’s requirements and its own policies. Specifically, we wanted to
determine whether it followed HUD’s and its own procurement requirements for its Recovery
Act formula grant activities.
4
RESULTS OF AUDIT
Finding 1: The Commission Did Not Always Comply With the
Recovery Act, HUD’s, and Its Own Procurement
Requirements
The Commission did not always comply with the Recovery Act, HUD’s, and its own
procurement requirements. Specifically, it did not adequately support the cost reasonableness of
its architectural services’ contracts and Recovery Act-funded projects. The deficiencies occurred
because the Commission lacked a sufficient understanding of HUD’s and its own requirements
and did not adequately monitor its architect. As a result, HUD and the Commission lacked
assurance that it paid reasonable prices for more than $960,000 in Recovery Act Capital Fund
formula grant projects.
The Commission Did Not
Adequately Support the Cost
Reasonableness of Recovery Act
Funded Activities
We reviewed 100 percent of the Commission’s procurement documentation
related to its two contracts for architectural services totaling more than $238,000
and four projects totaling nearly $723,000 (the scattered sites basement
waterproofing; the Atherton East Apartments repair and replacement of
sidewalks, porches, and steps; the force account labor unit renovations; and the
Howard Estates exterior renovation projects) to determine whether procurements
were conducted in accordance with HUD’s and the Commission’s requirements
during the period of March 18, 2009, through March 17, 2012.
The Commission generally planned for its Recovery Act projects and selected the
appropriate method of procurement in accordance with Recovery Act and HUD’s
requirements. However, the Commission did not evaluate the proposals for
architectural services in accordance with HUD’s or its own requirements.2
Specifically, the procurement file did not include documentation of the
architectural firms’ written cost proposals. Also, the Commission did not
maintain documentation showing that it negotiated with the firms to arrive at a
fair and reasonable cost.
The Commission also did not maintain in its procurement files the source
documentation for the independent cost estimates prepared for the scattered sites’
basement waterproofing project; the Atherton East project to repair or replace the
2
24 CFR (Code of Federal Regulations) 85.36(f) and the Commission’s Capital Fund Stimulus Grant procurement
policy, and request for proposals for architectural and engineering services.
5
sidewalks, porches, and steps; and the Howard Estates’ exterior renovation
project. Since it was a troubled public housing agency, execution of the Recovery
Act annual contributions contract amendment was the Commission’s agreement
to additional monitoring and oversight by HUD as deemed necessary to ensure
proper use of the Recovery Act capital funds. This additional oversight included
following the obligation submission approval requirements, which required the
Commission to submit an independent cost estimate and identify the source of
data used to develop the cost analysis (for instance, historical means, previous
contracts, etc.). However, neither the Commission nor its architect was able to
provide the source data to support the cost reasonableness for these three projects.
Further, the Commission did not maintain support showing that it was cost
effective to use force account labor to perform unit renovations. The Commission
used the winning bid from a sealed bid procurement performed in 2007 and
compared the per unit costs for using a contractor ($33,508 per unit) against using
force account labor ($22,000 per unit) to support the cost effectiveness of using
force account labor. However, the Commission did not maintain documentation
to support the estimates, and the estimates were based upon costs for a HOME
Investment Partnerships Program grant project, not the Recovery Act formula
grant.
The actual costs incurred by the Commission for the Recovery Act formula grant
averaged $5,000 per unit, which is a significant difference from the estimate
submitted to HUD by the Commission. Therefore, we were unable to evaluate the
estimates submitted by the Commission since the work performed was not the
same and the Commission could not detail what work was done in each unit. In
addition, the contractor’s estimates were nearly 2 years old. According to section
VII of Public and Indian Housing Notice 2009-12 and section 10.2 of HUD
Handbook 7485.3G, the use of force account labor must be approved only when it
is cost effective and appropriate to the scope and type of physical improvements
and the authority has the capacity to serve as its own main contractor and
maintain an adequate level of routine maintenance during force account activity.
Inadequate Cost Analysis
Neither the Commission nor its architect performed a cost analysis in accordance
with HUD’s requirements for the Atherton East Apartments project to repair or
replace the sidewalks, porches, and steps. The bid package for this project
included a cost breakdown form, document 00405, which required all bidders to
submit costs for various items of work, including demolition and excavation,
masonry porch structures, concrete porch slab, handrails and guards, concrete
steps, sidewalk replacement, landscape restoration, allowance, general conditions,
overhead and profit, and bond. The Commission and its architect stated that their
review of the bid submissions included only those documents requested of all
6
bidders (including document 00405), and they looked only at the total amount for
the project, not the individual line items as required by HUD.3
However, we determined that the individual line items indicated on the cost
breakdown form were used to evaluate some bid submissions but not all.
Specifically, the lowest bidder for this procurement was Sorenson Gross
Construction Services. The Commission and its architect CLM Architects, LLC
determined that the dollar value submitted by this contractor appeared too low for
the handrails and guards work item. Therefore, Sorenson Gross Construction
Services was contacted for clarification of its bid regarding this individual work
item, and the Commission and its architect determined this bidder to be
nonresponsive because the cost for this work item was determined to be
materially unbalanced. The next lowest and ultimately winning bidder was
Superior Contracting Group. The various work items were not used to evaluate
this bidder. Instead, the Commission and its architect CLM Architects, LLC
relied only on the bottom line amount, although the total amount of the work
items indicated by Superior Contracting Group on the cost breakdown form was
nearly $24,000 less than the total bid amount indicated on the form. In addition,
this contractor’s dollar amount of $6,950 for the masonry porch structures work
item appeared low in comparison to the architect’s reformatted independent cost
estimate of $25,185 and the other bidders’ estimates of $56,376 and $63,325 for
the same work item.
The Commission Lacked
Adequate Procedures and
Controls
The Commission lacked a sufficient understanding of HUD’s and its own
procurement and Recovery Act requirements. The Commission did not
adequately monitor the architects’ work for the Recovery Act formula grant
activities. According to the Commission’s modernization director, the sources of
data for the independent cost estimates prepared by the Commission’s architects
were not obtained because the Commission relied on the architects’ estimates the
same way it would rely on pricing information retrieved online, such as the RS
Means Construction Cost Estimate.4 Additionally, the Commission did not
perform a cost analysis for the Atherton East Apartments project to repair or
replace the sidewalks, steps, and porches because the contract was awarded based
upon the lowest responsive bidder since the sealed bids method of procurement
was used.
The Commission could not explain how the independent cost estimates were used
to determine the reasonableness of the contractors’ proposed costs or evaluate the
3
HUD Handbook 7460.8, REV-2, paragraphs 10.3.A and 6.12.E
4
An online database that provides cost information to the construction industry so contractors in the industry can
provide accurate estimates and projections for their project costs. It has become a data standard for government
work in terms of pricing and is widely used by the industry as a whole.
7
separate elements that make up a contractor’s total cost proposal or price to
determine whether the costs are allowable, directly related to the requirement, and
reasonable as required by HUD.5 The modernization director said that she had
used the independent cost estimates only to assist in determining how much the
Commission could budget for a project, not to evaluate the bids that were
submitted by the contractors.
Conclusion
The Commission lacked a sufficient understanding of HUD’s and its own
requirements and did not adequately monitor its architect. As a result, HUD and
the Commission lacked assurance that it paid reasonable prices for more than
$960,000 in Recovery Act Capital Fund formula grant projects.
Recommendations
We recommend that the Director of HUD’s Detroit Office of Public Housing
require the Commission to
1A. Provide sufficient documentation to support the reasonableness of $960,904
in expenses or reimburse HUD $935,412 ($960,904 - $2,147 - $12,165 -
$8,554 - $1,820 - $429 - $377)6 for transmission to the U.S. Treasury for the
unsupported costs cited in this finding.
1B. Develop and implement an adequate contract administration system that
complies with HUD’s and its own procurement requirements.
5
HUD Handbook 7460.8, REV-2, paragraph 10.3.A
6
The reduced amounts were included as part of the recommendations in finding 2.
8
Finding 2: The Commission Did Not Always Comply With HUD’s and
Its Own Contract Management Requirements
The Commission did not (1) issue payments to its contractor in accordance with HUD’s
requirements for one project, (2) adequately manage its force account labor unit renovations
project, and (3) ensure that its employees were paid the appropriate Federal labor standard wage
rates as required by the Davis-Bacon Act. The deficiencies occurred because the Commission
lacked an adequate contract administration system to ensure compliance with HUD’s and its own
requirements. Further, its staff lacked a sufficient understanding of Federal and its own
procurement requirements. As a result, it (1) underpaid nearly $22,000 to its 20 force account
labor employees and (2) overpaid more than$2,100 due to duplicate payments and nearly $2,200
due to incomplete work. Further, HUD and the Commission lacked assurance that more than
$21,000 in wages, taxes, appliances, materials and supplies was for its Recovery Act funded
projects.
Contract Payments Were Not
Issued in Accordance With
HUD’s Requirements
The Commission made progress payments to its contractor, Superior Contracting
Group, for the Atherton East Apartments project to repair or replace the
sidewalks, steps, or porches and to CLM Architects, LLC for architectural
services performed. However, it failed to ensure that work was completed in
accordance with the contract and supporting documentation before it paid for the
work.7 As of December 2010, Superior Contracting Group had submitted
invoices totaling $147,000 for the entire cost associated with this project.
According to the invitation for bids, the contractor’s bid submissions, and the
executed contract, this project involved work at 10 buildings. However, during
walk-through observations performed on April 17, 2013, we determined that 1 of
the 10 buildings did not receive any repairs or replacement of sidewalks, steps, or
porches. However, the Commission failed to deduct the costs of the activities that
were not completed from the progress payments made for this project.9
Based on the independent cost estimate for this project, we estimated that the cost
to repair or replace the sidewalks, porches, or steps at building 17 was $1,820 (for
a small single unit). In addition, since the Commission’s architect oversaw this
project, it did not provide adequate contract administration services under its
agreement with the Commission. The architect’s invoices indicated that $3,765
was allocated for the construction phase of the Atherton East project. Since the
work at 1 of 10 buildings for this project was not completed, we estimated that
$377 ($3,765 x 1/10) was inappropriately paid to the architect due to the lack of
oversight.
7
HUD Handbook 7460.8, REV-2, paragraph 11.2.E.7(c)
9
As a result of our audit, the Commission provided documentation that the repair
or replacement of sidewalks, porches, or steps at building 17 of Atherton East
Apartments was completed in accordance with contract documents in July 2013.
However since this project was completed after the Recovery Act expenditure
deadline of March 17, 2012, the Recovery Act formula grant funds associated
with this work was ineligible.
The Commission’s Force
Account Labor Unit
Renovations Were Not
Adequately Managed
The Commission did not adequately manage its force account labor unit
renovations as required by HUD.8 Specifically, it did not provide adequate
supporting documentation, such as purchase orders, labor logs, inspection reports,
and inventory records, for more than $21,000 in payments for materials and
supplies, wages and taxes, and appliances. The Commission inappropriately drew
down funds through HUD’s Line of Credit Control System to pay duplicate
expenses and purchase an appliance that was installed in a housing unit that was
not part of a Recovery Act-funded project. The following table shows the total
amount of unsupported and ineligible expenses incurred by the Commission for
its force account labor.
Unsupported Ineligible
Payment description payments payments
Materials and supplies $12,165 $0
Wages and taxes 8,554 0
Materials and supplies 0 $2,147
Appliances $429 0
Total $21,148 $2,147
The Commission Did Not
Ensure That Its Employees
Were Adequately Compensated
For the three contractual agreements reviewed, the Commission generally
complied with the requirements of the Davis-Bacon Act. However, the
Commission failed to pay the prevailing wage rate for the unit renovations
performed by its force account labor employees in accordance with HUD’s
requirements.9 As a result, 20 of its temporary employees were underpaid a total
of $21,861 in wages.
8
Section VII of Public and Indian Housing Notice 2009-12 and HUD Handbook 7485.3G, paragraph 10.2
9
24 CFR 968.110(e)
10
The Commission Did Not
Comply With HUD’s
Requirements
The Commission lacked an adequate contract administration system to ensure
compliance with HUD’s and the Commission’s requirements.10 Further, its staff
lacked a sufficient understanding of Federal and its own procurement
requirements. The Commission’s modernization director said she did not know
why all of the work for the Atherton East Apartments project to repair or replace
the sidewalks, porches, or steps was not completed. However as previously
discussed, the Commission provided documentation that the contractor completed
the work at building 17 of Atherton East Apartments in July 2013 (after the
expenditure deadline of March 17, 2012).
Further, according to the Commission’s modernization director, the former
executive director hired a modernization special project coordinator to oversee the
force account labor employees and did not allow her to supervise the work of the
coordinator, who generally prepared the purchase orders. However, all staff
employees received a copy of the Commission’s procurement policy; therefore,
he should have been aware of the purchase order requirements. The
modernization director said that the former executive director allowed the
coordinator to purchase additional items under previously prepared purchase
orders. Regarding the duplicate payments, the modernization director said she did
not know how the invoices were submitted for payment twice. However, she had
contacted the vendor and taken steps to resolve the duplicate payments.
Wages and taxes for the force account labor unit renovations were unsupported
because the Commission did not always consider the different funding sources
when preparing requisitions for HUD’s Line of Credit Control System. Initially,
the modernization director provided the personnel director with a breakdown of
each employee’s work, with consideration of work performed for the grant.
However, these procedures were not continued when the coordinator was
assigned the responsibility of overseeing the force account labor employees.
Therefore, the personnel director no longer received a breakdown of the work
performed. Instead, the requisitions were based solely upon the employees’
timecard reports, without consideration of the recorded information indicated on
the employees’ labor logs for the force account labor.
The Commission did not pay its force account labor employees Davis-Bacon
wages because the modernization director said that HUD had previously told her
that the Commission’s regular maintenance wages could be applied. However,
she was not familiar with HUD’s requirements concerning the Recovery Act
10
24 CFR 941.402(b), the Commission’s Capital Fund Stimulus Grant procurement policy, and 24 CFR 85.40(a)
11
formula grant. In addition, she said that HUD’s criteria regarding the use of HUD
determined wages versus the Davis-Bacon wage rates were not clear.
Conclusion
The Commission lacked an adequate contract administration system to ensure
compliance with HUD’s requirements. Further, its staff lacked a sufficient
understanding of Federal and its own procurement requirements. As a result, it
(1) underpaid nearly $22,000 to its 20 force account labor employees and (2)
overpaid more than $2,100 due to duplicate payments and nearly $2,200 due to
incomplete work. Further, HUD and the Commission lacked assurance that more
than $21,000 in wages, taxes, appliances, materials and supplies was used for its
Recovery Act-funded projects.
Recommendations
We recommend that the Director of HUD’s Detroit Office of Public Housing
require the Commission to
2A. Provide documentation or reimburse HUD $12,165 for transmission to the
U.S. Treasury for the materials and supplies for its force account labor unit
renovations due to missing or inadequate purchase orders, invoices,
receipts, or inventory records cited in this finding.
2B. Provide documentation or reimburse HUD $8,554 from the appropriate
fund for transmission to the U.S. Treasury for its force account labor
employees due to missing labor logs or labor logs that indicated work on
projects other than the Recovery Act formula grant work.
2C. Reimburse HUD $2,147 from its capital funds for transmission to the U.S.
Treasury for the duplicate payment made for its materials and supplies for
its Recovery Act formula grant force account labor unit renovations.
2D. Reimburse HUD $2,197 from its capital funds for transmission to the U.S.
Treasury for the work at building 17 of Atherton East Apartments
completed after the expenditure deadline of March 17, 2012.
2E. Provide sufficient documentation to support that the appliance was
installed in a unit renovated under the Recovery Act formula grant or
reimburse HUD $429 from its capital funds for transmission to the U.S.
Treasury.
2F. Develop and implement an adequate contract administration system to
ensure that its contracts and projects are managed in accordance with
HUD’s requirements and the Commission’s procurement policy.
12
We recommend that the Director of HUD’s Detroit Office of Labor Relations
require the Commission to
2G. Reimburse its 20 temporary employees $21,861 from its capital funds for
the wages paid for the force labor unit renovations that were less than
required by the Davis-Bacon Act.
2H. Develop and implement adequate written procedures and controls to
ensure that its employees are paid at the appropriate Federal prevailing
wage rates for covered contracts or work and provide training to its
employees on Federal labor requirements.
13
SCOPE AND METHODOLOGY
We performed our onsite audit work between December 2012 and June 2013 at the
Commission’s office located at 3820 Richfield Road, Flint, MI. The audit covered the period
March 18, 2009, through March 17, 2012, but was expanded when necessary to include other
periods.
To accomplish our objective, we reviewed
Applicable laws; regulations; Federal Register notices; HUD’s program requirements at
24 CFR (Code of Federal Regulations) Parts 85, 902, 905, 941, 965, and 968; 29 CFR
Parts 5 and 541; HUD public and Indian housing notices; HUD Handbook 7460.8, REV-
2; HUD Handbook 7485.3G; HUD Guidebook 7510.1; the United States Housing Act of
1937 as amended; Office of Management and Budget (OMB) requirements at 2 CFR Part
225; OMB Circular A-133; and OMB Memorandums M-09-10, M-09-15, M-09-21, M-
10-08, M-10-14, M-10-17, and M-10-34.
The Commission’s accounting records; annual audited financial statements for fiscal
years 2008, 2009, and 2010; bank statements; general ledgers; contract and procurement
files; policies and procedures; board meeting minutes for March 2009 through September
2011; organizational charts; program annual contributions contract with HUD; and
HUD’s Line of Credit Control System information and request for payment. Assessment
of the reliability of the data in this system was limited to the data sampled, which was
reconciled to Commission’s records.
HUD’s files for the Commission.
We also interviewed the Commission’s employees and HUD staff.
Finding 1
We reviewed the Commission’s architectural contracts and statistically selected four additional
projects to determine whether the Commission followed HUD’s and its own requirements during
the contract administration process during the period March 18, 2009, through March 17, 2012.
These contracts and projects included (1) the architectural and engineering contract with CLM
Architects; (2) the scattered sites basement waterproofing project; (3) the Atherton East
Apartments project to repair or replace sidewalks, porches, or steps; (4) the force account labor
unit renovation project; and (5) the Howard Estates exterior renovation project. The total
amount of Recovery Act funds spent on the contracts and projects reviewed totaled more than
$900,000.
Finding 2
We used the one contract and four projects selected in finding 1 to review the Commission’s
contract management process during the period March 18, 2009, through March 17, 2012.
14
For our site observations, we performed a 100 percent review of the scattered site basement
waterproofing activity. We used data mining software to statistically select five buildings to
observe the repair or replacement of sidewalks, porches, and steps at Atherton East Apartments
and five buildings to observe the exterior renovations at Howard Estates Apartments. We were
unable to perform site observations for the force labor unit renovations since the Commission did
not maintain documentation of the type of work that was performed and the type of materials or
supplies that were used in each of the 49 units renovated.
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.
15
INTERNAL CONTROLS
Internal control is a process adopted by those charged with governance and management,
designed to provide reasonable assurance about the achievement of the organization’s mission,
goals, and objectives with regard to
Effectiveness and efficiency of operations,
Reliability of financial reporting, and
Compliance with applicable laws and regulations.
Internal controls comprise the plans, policies, methods, and procedures used to meet the
organization’s mission, goals, and objectives. Internal controls 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
objectives:
Effectiveness and efficiency of operations – Policies and procedures that
management has implemented to reasonably ensure that a program meets its
objectives.
Reliability of financial reporting – 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 applicable laws and regulations – Policies and procedures
that management has implemented to reasonably ensure that resource use is
consistent with laws and regulations.
We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does
not allow management or employees, in the normal course of performing their
assigned functions, the reasonable opportunity to prevent, detect, or correct (1)
impairments to effectiveness or efficiency of operations, (2) misstatements in
financial or performance information, or (3) violations of laws and regulations on a
timely basis.
Significant Deficiencies
16
Based on our review, we believe that the following items are significant deficiencies:
The Commission did not comply with the Recovery Act, HUD’s, and its
own procurement requirements (see finding 1).
The Commission lacked adequate procedures and controls to ensure
compliance with HUD’s and its own contract management requirements for
its Recovery Act formula grant (see finding 2).
17
APPENDIXES
Appendix A
SCHEDULE OF QUESTIONED COSTS
AND FUNDS TO BE PUT TO BETTER USE
Recommendation Unsupported Funds to be put
Ineligible 1/
number 2/ to better use 3/
1A $935,412
2A $12,165
2B $8,554
2C $2,147
2D $2,197
2E $429
2G $21,861
Totals $4,344 $956,560 $21,861
1/ Ineligible costs are costs charged to a HUD-financed or HUD-insured program or activity
that the auditor believes are not allowable by law; contract; or Federal, State, or local
policies or regulations.
2/ Unsupported costs are those costs charged to a HUD-financed or HUD-insured program
or activity when we cannot determine eligibility at the time of the audit. Unsupported
costs require a decision by HUD program officials. This decision, in addition to
obtaining supporting documentation, might involve a legal interpretation or clarification
of departmental policies and procedures.
3/ Recommendations that funds be put to better use are estimates of amounts that could be
used more efficiently if an 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.
18
Appendix B
AUDITEE COMMENTS AND OIG’S EVALUATION
Ref to OIG Evaluation Auditee Comments
FLINT HOUSING COMMISSION
3820 Richfield Rd. ● Flint, Michigan 48506
Phone: (810) 736-3050
August 27,2013
MI 9-1
Richert Manor
902 E. Court St. 48503
(810) 736-3094 Kelly Anderson
MI 9-1 Regional Inspector General for Audit- Region 5
Garland Apartments U.S. Department of Housing and Urban Development
820 & 906 Garland St. 48503
(810) 736-3094 Office of Inspector General
MI 9-1 77 West Jackson Blvd.
Forest Park Chicago, IL 60604
4060 M.L King Ave. 48505
(810) 736-3094
MI 9-2 Dear Ms. Anderson:
Howard Estates (Family)
801 Flora Park 48503
(810) 234-4614
In response to the draft, report of your audit dated August 9, 2013 and your Exit
MI 9-3 Conference on August 22, 2013, regarding the American Recovery and
Atherton East (Family)
3123 Chambers 48507 Reinvestment Act Capital Fund Formula Grant 2009S,the Flint Housing Commission
(810) 743-4810
would like to give our written comments.
MI 9-5
River Park Apartments
(Family) In response to Finding #1:
7002 Pemberton Dr. 48505
(810) 789-3464 The Flint Housing Commission disagrees with the statement that the FHC failed to
MI 9-6
consider cost effectiveness or that expenditures are unsupported.
Centerview Apartments
2001 N. Center Rd. 48506
The Flint Housing Commission acted within reason with hiring architectural firms to
Comment 1 MI 9-8 & MI 9-10
supply bid packages for the 2009S ARRA grant. We signed the ACC for the 2009S
Scattered Site Houses
(Family)
ARRA Grant on March 3, 2009 and were told that HUD need the ACC's in to them by
MI 9-11 March 9, 2009 in order to release the funds to the Housing Commission by March
Mince Manor (Elderly)
3800 Richfield Rd. 48506 18, 2009. We believe this meant we were receiving the grant funds.
(810)736-3377
MI 9-14 The FHC believed, from the ACC,that we would receive funding, so the FHC put out an
Aldridge Place (Family)
ad and a request for proposals on March 8, 2009 for architectural firms to
Comment 1 5838 Edgar Holt Drive 48505
(810) 785-8102
handle the work that would be in the ARRA grant. In the Request for Proposals, it
MI 9-15 stated on page 6 of the request, "If the funds for the grant do not get approved or
Kenneth M. Simmons Square
2102 Stedron 48504 released, the funds for the architect/engineering fees will not be available and any
(810) 787-5910
and all contracts will be null and void." Contracts were not signed until April 27,
Section 8 Program 2009, 40 days after we were notified the funds were released.
(810) 736-3050
Section 3 Program
(810) 736-3050
Family Self-Sufficiency
Program
(810) 736-3050
Fax: (810) 736-0158
19
Ref to OIG Evaluation Auditee Comments
The Flint Housing Commission's committee choosing the architectural firm(s) read
Comment 2 all proposals, rated all proposals, interviewed the top three candidate and
negotiated with the best firms for t he amount of the contract based on information
we had on file. This is per our Procurement and HUD's Procurement Policy.
All bid packages and contracts were viewed by the architects and recommendations
Comment 3 were given to the Housing Commission. The lowest bidder, in all but one case, was
the bid that was approved, per HUD regulation CFR 24, Part 85.36, 12 (d)(2)(D). In
one instance, the contractor left out a large amount of material and admitted that
in his written review. He was deemed un-responsive and we went to the next low bidder.
The Flint Housing Commission did comply with the Recovery Act, HUD's and our
Comment 4 own Procurement requirement in hiring architects, we did monitor the architectural
work, and since we used low bidder on the projects, we had assurance that we paid
reasonable prices for all our contracts with the Recovery Act Capital Fund Grant
Formula Grant 2009S.
In Response to Finding #2:
Comment 5 In response to Finding #2, the Flint Housing Commission believes it has an adequate
contract administration system in place.
Since the Flint Housing Commission has been given permission in the past, from the
Department of Labor, to pay our temporary employees,who did work through the
Comment 6
grant, to be paid as a "Maintenance Tech", the FHC was under the understanding
that if the work was work that maintenance usually does (on their job descriptions),
then we could pay them the maintenance wage to do the same work.
The Flint Housing Commission has already responded to the OIG regarding the
Comment 7 change of work that was not recorded in the files properly. This work has been
Comment 8 completed and the information submitted to the OIG. In regards to appliances, the
FHC removes appliances from units when a move out occurs. These appliances may
be installed into a different unit.
Terrence Clark
Executive Director
CC: Anthony Smith, OIG; Richard Wears; Dan Micoff
20
OIG Evaluation of Auditee Comments
Comment 1 Based upon additional documentation provided by HUD, the deficiency regarding
the ineligible obligation related to the architectural and engineering services has
been removed from the audit report.
Comment 2 The Commission's procurement and capital fund stimulus grant procurement
policies states that for the competitive proposals procurement method, the
proposals must be evaluated only on the criteria stated in the request for
proposals. They also state that the Commission must maintain records sufficient
to detail the significant history of each procurement action. These records should
include the basis for contract price.
The Commission's request for proposals for its architectural and engineering
services, states that in evaluating proposals, the Commission would contact and
request written cost proposals. However its procurement files did not include
written cost proposals that were submitted by the top three firms. The request for
proposal also states that the Commission would then select and negotiate with that
firm to arrive at a fair and reasonable cost. In the event that an agreeable price
cannot be obtained, the Commission would begin negotiations with the next lower
ranked firm and so on until an agreement has been reached. However, the
Commission's procurement files did not include documentation to support that
negotiations occurred with the two firms that were awarded the architectural and
engineering services contract.
Further, in its obligations submission approval requirements package, dated July
30, 2009, the Commission stated that costs were negotiated using past
architectural and engineering fees and the State of Michigan architectural fee
schedule. The type of work being completed also played a part in the cost of the
architectural fees. However, the Commission did not provide a copy of the
previous architectural and engineering fees, and the architectural fee schedule,
which was from 2003, did not provide detail of the Commission's analysis of
costs.
During the course of the audit, the Commission did not (1) provide documentation
that it evaluated the proposals for its architectural and engineering services in
accordance with the request for proposals and its own procurement policy or (2)
provide the previous architectural and engineering fees or the details of its
analysis of the State of Michigan’s architectural fee schedule that were used to
negotiate costs. Therefore, we determined that it lacked sufficient support that the
cost for these services was reasonable.
Comment 3 The audit report has been revised to indicate that neither the Commission nor its
architect performed a cost analysis for the Atherton East Apartments project to
repair or replace the sidewalks, porches, and steps in accordance with HUD's
requirements. As indicated in the report, the instance where the contractor left out
21
a large amount of material pertained to Sorenson Gross Construction Services'
dollar value submitted for the handrails and guards work item.
The report acknowledges that the Commission and its architect performed a cost
analysis on Sorenson Gross Construction Services’ individual work items.
However, an adequate cost analysis was not performed for the individual work
items of the winning bidder Superior Contracting Group. Because the
Commission did not perform a cost analysis in accordance with HUD's
requirements (specifically, 24 CFR 85.36(f)(1) and paragraphs 10.3.A and 6.12.E
of HUD Handbook 7460.8, Rev-2), the nearly $24,000 difference in the total of
the individual line items and the total bid amount indicated on the cost breakdown
form submitted by Superior Contracting Group was not accounted for. In
addition, the contractor's cost for its masonry porch structure work item appeared
low in comparison to the architect's independent cost estimate and the other
bidders' estimate, but this difference was not evaluated.
Comment 4 We disagree with the Commission that it complied with Recovery Act, HUD’s
and its own procurement requirements in monitoring its architectural work and
assuring reasonable prices for its contracts and projects. As indicated in the audit
report and comment 2, the Commission did not properly evaluate its architects’
cost proposals in accordance with its policies. Further, it did not always (1)
maintain documentation to support independent cost estimates or (2) perform
adequate cost analyses for its Recovery Act projects to ensure it paid reasonable
prices.
Comment 5 We disagree with the Commission that it had an adequate contract administration
system. The audit scope was limited to the period covering the Recovery Act
formula grant. Based on the deficiencies cited in both the contract management
and contract administration processes, discussed in findings 1 and 2, the
Commission did not have an adequate contract administration system for its
Recovery Act formula grant.
Comment 6 The Commission did not provide documentation from the Department of Labor
regarding permission to pay temporary employees its maintenance technician
wages. Rather, the Commission provided documentation in which a HUD labor
relations specialist stated in August 2011 that temporary employees who replaced
doors on units at one of its apartment complexes could be paid at the rate of the
Commission's maintenance tech. However, there was no discussion of Davis-
Bacon wage requirements in this correspondence. Further, the work performed in
renovating its vacant units, based upon the invoices provided, did not just involve
replacing doors. Instead, development-type work was performed, including
countertop installations, window installations, floor installations, electrical work
(due to the purchase of receptacles), cleaning, painting, and other work.
HUD's regulations and policies (including HUD’s Frequently Asked Questions
#2, dated October 5, 2009 and 24 CFR 968.110(e)) indicate that the Davis-Bacon
wage rates were applicable for the Recovery Act capital fund formula grant. In
22
addition, HUD’s Labor Relations Letter 2004-02 states that force account
employees are entitled to receive no less than the wages determined to be
prevailing pursuant to the Davis-Bacon Act (for development work) and the
prevailing wages determined or adopted by HUD (for operations work). HUD’s
Making Davis-Bacon Work Guidance states that Davis-Bacon wage rates must be
paid to all laborers and mechanics employed in the development. This means the
force account labor must receive the prevailing wages applicable to the work they
perform.
Since the Commission's documentation did not indicate what type of work was
performed in each unit or by each employee for the duration of the force account
labor unit renovation project, the Davis-Bacon wage rate was applied to all
temporary employees who participated in this Recovery Act project.
Further, the Commission's executive director was instructed by HUD, in email
correspondence dated October 8, 2009, to follow the applicable labor standards
for its force account labor, including Davis-Bacon wage rates.
Comment 7 We agree with the Commission that it provided documentation regarding the
incomplete work discussed in finding 2. The audit report has been revised to
reflect that the Commission completed the repair or replacement of sidewalks,
porches, or steps at building 17 of the Atherton East Apartments in accordance
with contract documents. However, since this work was completed after the
expenditure deadline of March 17, 2012, the cost associated with the work is still
an ineligible expense of the Commission's Recovery Act capital fund formula
grant.
Comment 8 During the administration of its Recovery Act formula grant, the Commission did
not maintain inspection records for each unit or inventory records of its
appliances. As a result of our audit, the Commission performed an inventory of
its appliances and provided its inventory records in July 2013, which included the
appliances purchased using Recovery Act funds for the force account labor unit
renovation project. These inventory records did not indicate (1) when the
appliances were installed in the units, (2) whether they were moved out of a unit,
or (3) whether they were transferred, as specified on its inventory log. Based on
these inventory records, we concluded that 3 of the 4 appliances purchased with
Recovery Act funds were installed in units renovated using Recovery Act funds.
However, the Commission did not provide documentation to support that the
fourth appliance was ever installed in a unit renovated using Recovery Act funds.
23
Appendix C
FEDERAL AND THE COMMISSION’S REQUIREMENTS
Finding 1
HUD’s Recovery Act Capital Fund Formula Grant Frequently Asked Questions #1, dated April
10, 2009, eligible use of funds, question 8 asked, “…some public housing agencies have made
obligations after Recovery Act enactment but before they have received the annual contributions
award. With proper support that these obligations are proper and in connection with Recovery
Act, will public housing agencies be able to pay costs incurred after enactment but before
receiving their annual contributions contract award from Recovery Act Capital Fund resources?”
HUD answered that “public housing agencies can begin to obligate Recovery Act funds starting
March 18, 2009. The public housing agency must be sure that any obligations it is recording
against Recovery Act funds is for new work that has not been previously obligated. Public
housing agencies should contact their local field office with questions regarding eligible
obligations.”
HUD regulations at 24 CFR 85.36(d)(4) define cost analysis as verifying the proposed cost data,
the projections of the data, and the evaluation of the specific elements of costs and profits.
HUD regulations at 24 CFR 85.36(f)(1) state that a cost analysis must be performed when the
offeror is required to submit the elements of its estimated cost.
HUD Handbook 7460.8, REV-2, paragraph 10.3.A, states that “for every procurement, public
housing agencies are required to perform a cost or price analysis to determine that the price is
reasonable. Public housing agencies should always compare the prices offered with the
independent cost estimate. While this initial cost estimate may not be sufficient for price
reasonableness, it can assist the contracting officer in determining the extent to which the
offerors understand the public housing agencies’ requirements. A cost analysis is an evaluation
of the separate elements that make up a contractor’s total cost proposal or price to determine
whether they are allowable, directly related to the requirement, and reasonable.”
Paragraph 10.3.E of the handbook states with respect to price reasonableness that the
procurement file should be documented to support the actions taken.
Paragraph 6.12.E of the handbook states that any bid may be rejected if the contracting officer
determines that the price is unreasonable. Determining a bid price to be unreasonable includes
not only the total price of the bid, but the prices for individual items as well. Any bid may be
rejected if the prices for any of the items are materially unbalanced (such as bidding a high price
for the first items and then low prices for later items).
Paragraph 7.2.E of the handbook states that price must be a factor in making awards. In terms of
evaluating price, a public housing agency has two options, which must be indicated in the
24
request for proposals: “(2) Where Price and Other Technical Factors are Considered. Under this
method, technical factors are first determined and offerors are ranked. Then, prices are
evaluated. The public housing agency can award to the offeror whose price and technical factors
are the most advantageous to the public housing agency. This method is also known as the
‘trade-off’ method in that the public housing agency trades-off, or weighs the importance of,
price versus technical factors. All amendments must be in writing.”
Paragraph 7.2.M of the handbook states that the evaluation of price is made using the cost and
price analysis techniques in Chapter 10 and other evaluation processes described in the request
for proposals.
Paragraph 7.2.N of the handbook states that after the evaluation committee has evaluated all
proposals, the contracting officer should determine a competitive range. The competitive range
includes the proposals that have a reasonable chance of being selected for award considering
their technical evaluation results and their proposed costs or prices. The contracting officer
analyzes the proposed cost or pricing information to decide whether the offers propose a
reasonable total cost or price. The contracting officer then considers the combination of
technical and cost (the “total package”) presented by each proposal to decide whether it should
be kept in the running for negotiations and possible award. Before conducting negotiations,
technical proposals included in the competitive range should be classified as acceptable,
potentially acceptable, or unacceptable. The competitive range, including the contracting
officer’s rationale for it, must be documented in the contract file.
The Commission’s Capital Fund Stimulus Grant procurement policy, adopted by its board of
commissioners on September 25, 2009, states the following:
Section III, Part D, states that the board of commissioners designates the executive director
as the contracting officer. The executive director is responsible for ensuring that
procurement actions comply with this policy. The executive director may delegate all or
some procurement authority as is necessary and appropriate to conduct the business of the
Commission. The executive director must appoint delegations of contract authority in
writing. The appointment should state the scope and limitations of authority. The executive
director or designee(s) must ensure that a cost or price analysis is conducted on responses for
all procurement actions that exceed $2,500.
Section IV.E.3 discusses evaluations and states that the proposals must be evaluated only on
the criteria stated in the request for proposals. When not apparent from the evaluation
criteria, the Commission should establish an appropriately appointed evaluation committee.
Section IV.E.4 discusses negotiations and states that unless there is no need for negotiations
with any of the offerors, negotiations should be conducted with offerors that submit
proposals determined to have a reasonable chance of being selected for award, based on
evaluation against the technical and price factors as specified in the request for proposals.
Regulations at 24 CFR 85.36(b)(9) state that grantees and subgrantees must maintain records
sufficient to detail the significant history of a procurement. These records must include but are
25
not necessarily limited to the following: rationale for the method of procurement, selection of
contract type, contractor selection or rejection, and the basis for the contract price.
The Commission’s request for proposals for architectural and engineering services, dated March
5, 2009, states that the housing authority will use the following procedure to evaluate proposals:
An evaluation panel (committee) of three or more members will be established. The evaluation
panel will evaluate the qualifications of all respondents. The committee will then interview the
top three firms. Then the top ranked firm, after the interviews, will be contacted and asked to
submit a written cost proposal. The housing authority will then negotiate with that firm to arrive
at a fair and reasonable cost. In the event that an agreeable price cannot be obtained, the housing
authority will begin negotiations with the next lower ranked firm and so on until an agreement
has been reached.
Finding 2
The American Recovery and Reinvestment Act of 2009, January 6, 2009, Public Law 111-5,
Section 1606, states that despite any other provision of law and in a manner consistent with other
provisions in the Act, all laborers and mechanics employed by contractors and subcontractors on
projects funded directly by or assisted in whole or in part by and through the Federal
Government based on the Act must be paid wages at rates not less than those prevailing on
projects of a character similar in the locality as determined by the Secretary of Labor in
accordance with subchapter IV of chapter 31 of Title 40, United States Code.
HUD’s Recovery Act Capital Fund Formula Grant Frequently Asked Questions #2, dated
October 5, 2009, general question 12, states that the Davis-Bacon wage requirements apply to
the activities funded with Recovery Act Capital Fund formula grants.
HUD regulations at 24 CFR 968.110(e) state that with respect to modernization work or
contracts over $2,000 (except for nonroutine maintenance work), all laborers and mechanics
(other than volunteers under the conditions set out in 24 CFR Part 70) who are employed by the
public housing agency or its contractors must be paid not less than the wages prevailing in the
locality, as predetermined by the Secretary of Labor based on the Davis-Bacon Act (40 U.S.C.
276a–276a–5).
HUD regulations at 24 CFR 968.140 state that it is the responsibility of the public housing
agency, not HUD, to provide, by contract or otherwise, adequate and competent supervisory and
inspection personnel during modernization, whether work is performed by contract or force
account labor and with or without the services of an architect or engineer, to ensure work quality
and progress.
HUD’s Procurement Handbook 7460.8, REV-2, paragraph 1.9, defines inspection as the
examination and testing of supplies and services to determine conformance with the contract
requirements.
Paragraph 11.2.C of the handbook states that the quality of the inspection is critical, and the
authority should ensure that either the architect, engineer, or designated person responsible for
26
inspection is fully qualified and performs the inspections frequently and thoroughly. “(1) All
progress inspections should be documented using an appropriate public housing agency
inspection report form. The inspection report should include a description of the work
completed and a determination as to whether or not the work is acceptable. If payment is made
on a unit price basis, quantities must be verified. If payment is made on a time and materials
basis, the report should show that the time charged was spent on public housing agency work and
that materials were charged at cost. A copy of the inspection report should be included in the
contract file. Based on the progress report, the contracting officer should initiate any needed
follow-up actions to ensure that the terms of the contract are being fulfilled.”
Paragraph 11.2.E.7(c) of the handbook states, “The public housing agency should review each
contractor request and should approve the payment if the following conditions have been met (if
the contractor requests payment for items that have not been acceptably completed, the authority
should delete those items and adjust the payment accordingly), including that the work has been
performed in accordance with the construction documents.”
HUD’s regulations at 24 CFR 941.402(b) state that the public housing agency must be
responsible for contract administration and should contract for the services of an architect or
other person licensed under State law to assist and advise the public housing agency in contract
administration and inspections to ensure that the work is done in accordance with HUD
requirements.
HUD’s regulations at 24 CFR 85.40(a) state that grantees are responsible for managing the day-
to-day operations of grant- and subgrant-supported activities. Grantees must monitor grant- and
subgrant-supported activities to ensure compliance with applicable Federal requirements and that
performance goals are achieved. Grantee monitoring must cover each program, function or
activity.
The Commission’s Capital Fund Stimulus Grant procurement policy, adopted by its board of
commissioners on September 25, 2009, states in Section IX.D that the Commission must
maintain a system of contract administration designed to ensure that contractors perform in
accordance with their contracts. These systems shall provide for inspection of supplies, services,
or construction, as well as monitoring contractor performance, status reporting on major projects
including construction contracts, and similar matters.
27
The Flint Housing Commission, Flint, MI, Did Not Always Administer Its Grant in Accordance With Recovery Act, HUD's, and Its Own Requirements
Published by the Department of Housing and Urban Development, Office of Inspector General on 2013-09-27.
Below is a raw (and likely hideous) rendition of the original report. (PDF)