The City of Albuquerque, NM, Generally Administered Its Continuum of Care Program in Accordance With Applicable HUD Regulations and Grant Agreements

Published by the Department of Housing and Urban Development, Office of Inspector General on 2015-01-13.

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

                                                     U.S. DEPARTMENT OF
                                    HOUSING AND URBAN DEVELOPMENT
                                             OFFICE OF INSPECTOR GENERAL

                                                          January 13, 2015
                                                                                                  MEMORANDUM NO:

TO:              Leticia Ibarra
                 Director, Community Planning and Development, 6BD

FROM:            Gerald Kirkland
                 Regional Inspector General for Audit, 6AGA

SUBJECT:         The City of Albuquerque, NM, Generally Administered Its Continuum of Care
                 Program in Accordance With Applicable HUD Regulations and Grant


We reviewed the City of Albuquerque, Department of Family and Community Services’
Continuum of Care program. We initiated the review based on a complaint alleging misconduct
in the City’s program. Specifically, the complainant alleged the City’s Continuum of Care failed
to comply with conflict of interest and procurement requirements, did not maintain accurate
Homeless Management Information System (HMIS) 1 reports, and expended funds for ineligible
activities. These issues involved compliance with various U.S. Department of Housing and
Urban Development requirements. Therefore, our objective was to determine whether the City
administered its program in accordance with applicable HUD regulations and grant agreements.

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.

    HMIS is a computerized data collection application that facilitates the collection of information on homeless
    individuals and families, using residential or other homeless assistance services, and stores the data in an
    electronic format.

                                                     Office of Audit (Region 6)
                                      819 Taylor Street, Suite 13A09, Fort Worth, TX 76102
                                           Phone (817) 978-9309, Fax (817) 978-9316
                                Visit the Office of Inspector General Website at www.hudoig.gov
                                  METHODOLOGY AND SCOPE

We reviewed the City’s program expenditures, procurement, monitoring, potential conflicts of
interest, and measurable results for the period October 1, 2011, through December 31, 2013. We
expanded the scope as necessary to meet the review objectives. We conducted the review at the
City’s office, St. Martin’s Hospitality Center’s administrative office, the HUD field office, and
our office in Albuquerque, NM, from May through August 2014.

To accomplish our objectives, we

    •   Reviewed relevant laws, regulations, applications, grant agreements, notices of funding
        availability, other HUD requirements and guidance, and various Office of Community
        Planning and Development (CPD) files related to the City’s program.
    •   Reviewed the City’s administrative requirements, organizational charts, audited financial
        statements, and general ledgers and the program’s governance charter.
    •   Obtained and compared the listings of Continuum of Care board members and City staff
        with those of subrecipients’ board members and staff to identify potential conflicts of
    •   Reviewed and analyzed the City’s monitoring reports and quarterly reports and the City’s
        procurement files for the review period.
    •   Selected and reviewed the last annual performance reports for St. Martin’s Shelter Plus
        Care and Supportive Housing programs.
    •   Compared the Albuquerque Continuum of Care HMIS client list with the St. Martin’s
        client lists.
    •   Reviewed HUD’s Line of Credit Control System 2 grant detail for the City’s Continuum
        of Care grants.
    •   Selected and tested a nonstatistical sample of 29 of 271 disbursements made by the City’s
        Department of Family and Community Services to determine whether the disbursements
        were supported and for eligible activities. The items selected included reimbursements of
        more than $640,000 from all grants and all subrecpients for each fiscal year. This
        number represents approximately 11 percent of the disbursements from October 2011
        through December 2013.
    •   Selected and reviewed nine client files at St. Martin’s to ensure that each client file
        existed and contained a lease or rental agreement and that the resident rent calculation
        worksheet amounts matched amounts billed to the City. We also traced five payments to
        St. Martin’s general ledger and check register to ensure that St. Martin’s paid the rents for
        the clients and recorded the transactions in the general ledger.
    •   Analyzed St. Martin’s financial records, including general ledgers, check registers, and
        supporting documentation.
    •   Interviewed HUD CPD representatives, City staff, and St. Martin’s and Continuum of
        Care officials and staff.

    The Line of Credit Control System is HUD’s primary grant disbursement system, handling disbursements for
    the majority of HUD programs.


The Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 amended the
Mckinney-Vento Homeless Assistance Act and consolidated the three separate McKinney-Vento
homeless assistance programs (Supportive Housing, Shelter Plus Care, and Section 8 Moderate
Rehabilitation Single Room Occupancy3) into a single grant program known as the Continuum
of Care program.

The Continuum of Care program was designed to assist sheltered and unsheltered homeless
people by providing the housing and services needed to help individuals move into transitional
and permanent housing, with the goal of providing long-term stability.

Each year, HUD awards Continuum of Care program funding competitively to nonprofit
organizations, States, and units of general purpose local governments, collectively known as
recipients. The City was one of the recipients. The City was also the lead agency that applied for
grants on behalf of the Albuquerque Continuum of Care. The City received four grants each year
and subgranted with nine nonprofit organizations, known as subrecipients, to carry out the
grants’ day-to-day program operations.
The total amount authorized for the City’s programs for fiscal years 2010 to 2012 was more than
$7.8 million. The City had expended more than $6.1 million of the funds as of December 31,

The City was required to administer its program according to its grant applications, agreements,
and HUD requirements.

                                        RESULTS OF REVIEW

The allegations of misconduct in the City’s Continuum of Care program did not have merit.
They were either invalid, or out of date. The City generally administered its program in
accordance with applicable HUD regulations and grant agreements. Specifically, it complied
with HUD procurement and conflict of interest requirements, adequately monitored the
subrecipients and took actions to correct problems it identified, and ensured that the
subrecipients expended the Continuum of Care program funds for eligible program activities.
However, the City needs to improve its reporting of measurable results. While the City
supported the progress reported to HUD in its annual performance reports, it did not maintain
accurate data supporting its measurable results.
A comparison of the client list for the Shelter Plus Care program, which St. Martin’s used to bill
the City for reimbursement in September 2013, with the HMIS client list showed that two clients
receiving assistance were not on the HMIS client list. The error had not been reported in the
2013 annual performance report because the report had not been submitted at the time of our

    The City did not have any Single Room Occupancy grants because it was no longer eligible under the
    Continuum of Care program.

In addition, the St. Martin’s client list for the Supportive Housing program showed assistance to
125 participants for the review period, while the HMIS performance report for the same period
reflected 126 participants. The HMIS project director explained that the discrepancy was caused
by a system error in HMIS.
The discrepancies appeared to be minor. However, the City needs to ensure that it reports
complete and accurate information to HUD regarding measurable results of its Continuum of
Care grants. Without reliable information, HUD and the City may incorrectly assess program
progress and accomplishments.


We recommend that the Director, Community Planning and Development, Albuquerque, NM,
require the City to

1A.    Develop and implement procedures to ensure that information in its annual performance
       reports is complete and accurate.


Appendix A


Ref to OIG Evaluation      Auditee Comments

Comment 1

Comment 1

                         OIG Evaluation of Auditee Comments

Comment 1   The Authority did not disagree with the audit memorandum or the
            recommendation, and outlined the steps that it has taken or is taking to improve
            its reporting of measurable results.