oversight

Allocation of Costs to the Waterbury Housing Authority Asset Management Projects Was Generally Supported

Published by the Department of Housing and Urban Development, Office of Inspector General on 2015-09-30.

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

          Waterbury Housing Authority,
                Waterbury, CT
      Allocation of Costs to Asset Management Projects




Office of Audit, Region 1       Audit Report Number: 2015-BO-1004
Boston, MA                                      September 30, 2015
To:            Jennifer Gottlieb Elazhari
               Program Center Coordinator, Office of Public and Indian Housing, Hartford Field
               Office, 1EPHP

               //SIGNED//
From:          Edward Jeye
               Regional Inspector General for Audit, Boston Region, 1AGA

Subject:       Allocation of Costs to the Waterbury Housing Authority Asset Management
               Projects Was Generally Supported


Attached is the U.S. Department of Housing and Urban Development (HUD) Office of Inspector
General’s (OIG’s) final results of our review of the Waterbury Housing Authority’s asset
management projects.
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 this 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
(617) 994-8380.
                    Audit Report Number: 2015-BO-1004
                    Date: September 30, 2015

                    Allocation of Costs to the Waterbury Housing Authority Asset Management
                    Projects Was Generally Supported




Highlights

What We Audited and Why
We audited the Waterbury Housing Authority’s administration of its asset management projects
based on a risk assessment that considered the U.S. Department of Housing and Urban
Development’s (HUD) risk assessment and the Authority’s funding and number of asset
management units. Our overall audit objective was to determine whether Authority officials
ensured that expenses charged to the Authority’s asset management projects complied with HUD
regulations.

What We Found
Authority officials generally supported the allocation of costs of more than $10 million to the
asset management projects. While adequate controls were established and implemented to
ensure that costs charged to the projects were supported, the allocation of one employee’s salary
to the projects was not adequately supported. This deficiency occurred because the Authority
lacked adequate procedures to track employee time spent on frontline and nonfrontline activities
to ensure that employee time was appropriately charged between its asset management projects
and central office cost center. As a result, one employee’s salary of $169,081, allocated to the
projects, was not adequately supported.

What We Recommend
We recommend that the program center coordinator of HUD’s Hartford Office of Public and
Indian Housing require the Authority to support $169,081 in salary costs charged to the asset
management projects or repay any unsupported amount from non-Federal funds.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................4
         Finding: Allocation of Costs Among the Asset Management Projects Was
                  Generally Supported ........................................................................................ 4

Scope and Methodology ...........................................................................................6

Internal Controls ......................................................................................................8

Appendixes ..............................................................................................................10
         A. Schedule of Questioned Costs .................................................................................. 10

         B. Auditee Comments and OIG’s Evaluation ............................................................. 11




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Background and Objectives
The Waterbury Housing Authority in Waterbury, CT, was created under section 8-40 of the
Connecticut General Statutes to provide low-income housing for qualified individuals. The
Authority is governed by a five-member board of commissioners, which appoints an executive
director to manage the day-to-day operations of the Authority. In fiscal year 2014, the Authority
received approximately $4 million in operating funds from the U.S. Department of Housing and
Urban Development (HUD) to assist in administering its 785 low-rent public housing units and
employed 33 full-time staff members.

Regulations at 24 CFR (Code of Federal Regulations) Part 990 established requirements for
public housing agencies to convert to asset management. Agencies with 250 or more units must
convert to asset management, while agencies with fewer than 250 units may voluntarily convert
to asset management. One of the major provisions under asset management is the requirement
that public housing agencies charge a reasonable management fee to projects and programs for
central office costs.

The Authority converted to asset management in fiscal year 2008, using the indirect allocation
method under which costs were tracked through its central office cost center and allocated to its
asset management projects. In fiscal year 2012, the Authority implemented a fee-for-service
methodology for all of its projects and programs, by which the cost of providing management
services is accumulated by its central office cost centers. The cost center charges and collects
fees from the projects (HUD establishes the type and amount of fees that public housing agencies
may charge to their projects).

Our audit objective was to determine whether Authority officials ensured that expenses charged
to the Authority’s asset management projects complied with HUD regulations.




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Results of Audit

    Finding: Allocation of Costs Among the Asset Management
    Projects Was Generally Supported
Authority officials generally supported the allocation of more than $10 million to their asset
management projects; however, they did not adequately support the allocation of one employee’s
salary. This deficiency occurred because the Authority lacked adequate procedures to track
employee time spent on frontline and nonfrontline activities to ensure that employee time was
appropriately charged between its asset management projects and central office cost center. As a
result, the salary cost of $169,081, allocated to the projects in fiscal years 2012 through 2014,
was not adequately supported.

Costs Allocated to the Asset Management Projects Were Generally Supported
The review of salary allocations to the asset management projects disclosed that Authority
officials adequately supported the allocation of salary costs of approximately $3 million but did
not adequately support the allocation of one employee’s salary. While the employee’s salary
was allocated 100 percent to the projects as a percentage of units, the employee’s position
included activities that should have been charged to the central office cost center. The
Supplement to HUD Handbook 7475.1, REV, CHG 1, Financial Management Handbook,
provides that a public housing agency with personnel who provide shared resources to asset
management projects and the central office cost center needs to separate the amount of time
spent on providing services to the projects and the cost center based on a reasonable
methodology. Also, HUD Handbook 4381.5, Management Agent Handbook, chapter 6,
“requires that an agent that employs staff at a property must develop a job description for each
generalist position outlining the frontline and non-frontline1 responsibilities of each position, and
document hours spent and duties performed on frontline activities for each project and those
spent on the central office functions.”
In fiscal years 2012 and 2013, the employee held the position of modernization coordinator, and
in fiscal year 2014, the employee held the position of operations assistant. The job descriptions
under both positions included tasks that were reasonably identified as central office functions.
For example, the duties of the modernization coordinator included budgeting, procurement of
construction, and preparation of quarterly reports. These duties should have been paid from the
central office cost center’s Public Housing Capital Fund management fee. In addition, the
operations assistant duties included trips to the bank, pickup and delivery of mail, maintenance



1
 Frontline responsibilities include activities directly related to the project, such as legal, auditing, and maintenance
services that may be charged to the project operating account. Costs for services that are nonfrontline, such as
Authority supervisory staff, must be paid out of management fee funds.




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of the Authority’s fleet, and ensuring that supply rooms were stocked. These duties should have
been paid from the cost center’s property management fee. This condition occurred because the
Authority lacked adequate procedures to track and appropriately allocate employee activities
between asset management projects and its central office cost center. The Authority tracked
employee hours, but did not support the hours spent on each activity. As a result, the salary cost
of $169,081, allocated to the projects for one employee, was not adequately supported.

Recommendations
We recommend that the program center coordinator of HUD’s Hartford Office of Public and
Indian Housing require the Authority to

       1A.     Provide documentation to support that the $169,081 paid to the employee, who
               served as the modernization coordinator in fiscal years 2012 and 2013 and the
               operations assistant in fiscal year 2014, was allocated properly to the asset
               management projects. Any unsupported amounts should be repaid from non-
               Federal funds.

       1B.     Strengthen controls over tracking the time and the allocation of salary for
               employees whose job descriptions include both frontline and nonfrontline duties
               to ensure that costs are properly charged to asset management projects and the
               central office cost center.




                                                 5
Scope and Methodology
The audit focused on whether Authority officials ensured that expenses charged to the
Authority’s asset management projects complied with HUD regulations. We performed audit
fieldwork from March to June 2015 at the Authority, 2 Lakewood Road, Waterbury, CT. Our
audit covered the period July 2011 through June 2014 and was extended when necessary to meet
our audit objective.

To accomplish our objective, we

          Reviewed applicable laws, regulations, HUD handbooks, HUD notices, and the
           Authority’s policies and procedures.

          Interviewed Authority officials to gain an understanding of the organizational
           structure and management of the asset management projects.

          Reviewed independent public accountant and HUD monitoring reports.

          Reviewed the board of commissioners’ meeting minutes.

          Analyzed job descriptions and $3 million in salary allocated to the asset management
           projects from July 2011 through June 2014 to evaluate the reasonableness of the
           allocation.

          Reviewed the approximately $3.4 million in fees charged by the central office cost
           center to the asset management projects for property management, book-keeping,
           asset management, and Housing Choice Voucher program fees from July 2011
           through June 2014 to evaluate the reasonableness of these fees.

          Reviewed approximately $3.1 million in employee benefits charged to the asset
           management projects from July 2011 through June 2014 to evaluate the
           reasonableness of these charges.

          Sampled six maintenance contracts to determine whether the contracts were properly
           procured and the costs were eligible.

          Sampled $80,168 of the $250,723 in legal costs incurred by the asset management
           projects from July 2011 through June 2014 to determine whether costs were
           reasonably allocated to the projects.

          Reviewed workmen’s compensation costs of $218,871 charged in fiscal years 2013
           and 2014 and property insurance costs of $162,085 charged in fiscal year 2014 to



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           determine whether these costs were allocated reasonably to the asset management
           projects.

          We limited our assessment of the reliability of the Authority’s accounting data to the
           data sampled, which reconciled to supporting documentation; therefore, we did not
           assess the reliability of the Authority’s computer processed data.

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(s). We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.




                                                7
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 objective:

   Effectiveness and efficiency of operations – Policies and procedures that management has
    implemented to reasonably ensure that a program meets its objectives.

   Reliability of financial data – Policies and procedures that management has implemented to
    reasonably ensure that valid and reliable data are obtained, maintained, and fairly disclosed in
    reports.

   Compliance with applicable laws and regulations – Policies and procedures that management
    has implemented to reasonably ensure that resources use is consistent with laws and regulations.

   Safeguarding of resources – Policies and procedures that management has implemented to
    reasonably ensure that resources are safeguarded against waste, loss, and abuse.

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 the 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.




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We evaluated internal controls related to the audit objectives in accordance with generally
accepted government auditing standards. Our evaluation of internal controls was not designed to
provide assurance regarding the effectiveness of the internal control structure as a whole.
Accordingly, we do not express an opinion on the effectiveness of the City’s internal control as a
whole.




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Appendixes

Appendix A
                              Schedule of Questioned Costs


                           Recommendation
                                                Unsupported 1/
                               number
                                   1A              $169,081
                                 Total             $169,081

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, may involve a legal interpretation or clarification of
     departmental policies and procedures.




                                              10
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 1




                               11
                         OIG Evaluation of Auditee Comments


Comment 1   Agency officials agreed that employee charges to the projects were not properly
            supported and believe that approximately 80 percent of the questioned costs were
            eligible costs to the projects. They said they will provide documentation to HUD
            to support those costs. Consequently, the auditee’s planned actions are responsive
            to the report recommendations, which will be resolved with HUD during the audit
            resolution process.




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