oversight

The Housing Authority of the County of San Bernardino, San Bernardino, CA, Used Shelter Plus Care Program Funds for Ineligible and Unsupported Participants

Published by the Department of Housing and Urban Development, Office of Inspector General on 2015-05-29.

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

   Housing Authority of the County of
   San Bernardino, San Bernardino, CA
                       Shelter Plus Care Program




Office of Audit, Region 9            Audit Report Number: 2015-LA-1004
Los Angeles, CA                                            May 29, 2015
To:            William G. Vasquez, Director, Office of Community Planning and Development,
               Los Angeles, 9DD
               //SIGNED//
From:          Tanya E. Schulze, Regional Inspector General for Audit, 9DGA
Subject:       The Housing Authority of the County of San Bernardino, San Bernardino, CA,
               Used Shelter Plus Care Program Funds for Ineligible and Unsupported
               Participants


Attached is the U.S. Department of Housing and Urban Development (HUD), Office of Inspector
General’s (OIG) final results of our review of the Housing Authority of the County of San
Bernardino’s Shelter Plus Care program.
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
213-534-2471.
                    Audit Report Number: 2015-LA-1004
                    Date: May 29, 2015

                    The Housing Authority of the County of San Bernardino, San Bernardino,
                    CA, Used Shelter Plus Care Program Funds for Ineligible and Unsupported
                    Participants



Highlights

What We Audited and Why
We audited the Housing Authority of the County of San Bernardino’s Shelter Plus Care program
due to a public complaint alleging that the Authority disregarded U.S. Department of Housing
and Urban Development (HUD) program requirements related to participants’ eligibility. Our
objective was to determine whether the Authority administered its program funds in accordance
with HUD rules and requirements, specifically related to participants’ eligibility.

What We Found
The complaint had merit. The Authority did not always ensure that its participants were eligible
for the program. Of 75 participants reviewed, 50 were ineligible for the program. We could not
validate the eligibility of eight participants because of missing documents. The Authority spent
more than $3.2 million in program funds on ineligible participants and participants whose
eligibility was not supported with documentation. If the Authority does not improve its controls,
it could pay at least $873,428 in program funds for ineligible participants in the next year.
Further, the Authority’s practices hampered its ability to accomplish HUD’s goal of ending
homelessness for individuals with disabilities and their families.

What We Recommend
We recommend that the Director of HUD’s Los Angeles Office of Community Planning and
Development require the Authority to (1) repay HUD more than $3.1 million from non-Federal
funds for program funds spent on ineligible participants, (2) provide supporting documentation
for $136,346 in program funds used for participants for whom eligibility could not be
determined, and (3) develop and implement written policies and procedures to ensure that
participants are eligible for the program and comply with HUD rules and requirements so that
$873,428 in program funds can be put to better use.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................4
         Finding: The Authority Did Not Ensure That Participants Were Eligible for the
         Program ............................................................................................................................. 4

Scope and Methodology ...........................................................................................8

Internal Controls ....................................................................................................10

Appendixes ..............................................................................................................11
         A. Schedule of Questioned Costs and Funds To Be Put to Better Use ...................... 11

         B. Auditee Comments and OIG’s Evaluation ............................................................. 12

         C. Criteria ....................................................................................................................... 32

         D. Summary of Review of Participant Eligibility ....................................................... 37




                                                                      2
Background and Objective
The Shelter Plus Care Program is an important source of permanent housing assistance for hard-
to-serve homeless individuals with disabilities and their families. The U.S. Department of
Housing and Urban Development (HUD) began awarding program funds in 1992 to State and
local governments and public housing agencies as a way to assist a population that has been
traditionally hard to reach. These individuals primarily include those with serious mental illness,
chronic problems with alcohol or drugs, and HIV-AIDS or related diseases. Local programs are
typically implemented through partnerships that include a grantee, one or more nonprofit
housing sponsors that own or coordinate leasing of housing for program participants, and a
network of supportive service providers. The program assists in HUD’s goal to end
homelessness.
The Housing Authority of the County of San Bernardino administers eight grants for its program.
To date, HUD has awarded the Authority more than $18 million in program funds, including
grant renewals. As of fiscal year 2015, HUD had approved the Authority to provide permanent
housing assistance for 195 units in accordance with its executed grant agreements.

Since July 1, 2012, the Authority has worked with the County of San Bernardino’s Department
of Behavioral Health, Office of Homeless Services, under a memorandum of understanding for
the administration of the program. Specifically, the County determines whether participants
meet the program’s homeless and disability requirements to enter the program. As part of the
eligibility process, it also obtains and reviews applications and documentation to support the
participants’ homelessness and disability. While the County provides technical assistance to the
Authority, the Authority is responsible for complying with program rules and requirements.

Participants are eligible for the program if they meet both homeless and disability requirements
as defined by HUD. Specifically, all participants must meet HUD’s definition of homeless stated
in 24 CFR (Code of Federal Regulations) 582.5 and the McKinney-Vento Homeless Assistance
Act, Section 103, and the Homeless Emergency Assistance and Rapid Transition to Housing Act
(HEARTH Act) 24 CFR 582.5. In addition, these participants must meet HUD’s definition of a
person with disabilities as defined in 24 CFR 582.5 and the HEARTH Act.

Our objective was to determine whether the Authority administered its program funds in
accordance with HUD rules and requirements, specifically related to participants’ eligibility.




                                                 3
Results of Audit

Finding: The Authority Did Not Ensure That Participants Were
Eligible for the Program
The Authority did not ensure that participants were eligible for program assistance. Of 75
participants reviewed, 50 were ineligible for the program because they did not meet homeless
and disability requirements. We could not validate the eligibility of eight participants because of
missing documents. This condition occurred because the Authority relied on the County to
determine the homeless and disability eligibility of participants without monitoring the process.
Further, its internal controls and procedures that outlined program requirements were
inconsistent with HUD’s requirements for determining participants’ homeless and disability
eligibility. As a result, the Authority spent more than $3.1 million in program funds on ineligible
participants and $136,346 on participants who did not have documentation to support their
eligibility. Unless the Authority improves its monitoring of participant eligibility, we estimate
that it will spend at least $873,428 next year for ineligible participants. Further, the Authority’s
practices created a risk of not meeting HUD’s goal of ending homelessness for individuals with
disabilities and their families within San Bernardino County.

The Authority Used Program Funds for Ineligible Participants
Of the 75 participants reviewed, the Authority incurred program costs for 50 who were ineligible
because they did not meet HUD’s definition of homeless or disability eligibility (see appendix
D).

Homeless Requirements Not Met
The Authority administered program funds under the homeless definition requirements in 24
CFR 582.5, effective April 1, 2008; the McKinney-Vento Homeless Assistance Act, Section 103,
effective May 20, 2009; and the Homeless Emergency Assistance and Rapid Transition to
Housing Act (HEARTH Act) 24 CFR 582.5, effective January 4, 2012. Of the 75 reviewed
participants, 33 were not homeless as defined by HUD (see appendix D). These participant files
included documentation that contradicted their status as homeless as defined by HUD rules and
requirements. At the time of the initial application intake, these participants resided in housing
and did not need program assistance. Yet they entered a program that was intended for
individuals considered homeless by HUD. For example, one participant claimed to be living
with family but was not “homeless” as defined by HUD. The participant’s family was in the
process of evicting the participant. However, the eviction letters were dated January 3, 2013,
after the application was submitted on December 26, 2012. The eviction letter stated that the
participant would lose residency within 45 days, resulting in the period of homelessness not
complying with the McKinney-Vento Homeless Assistance Act or the HEARTH
Act. Specifically, both definitions state that participants must be losing their housing within 14
days of applying for the program. In this case, the participant’s application was submitted more
than 14 days before the Authority needed to provide assistance. During this period, the
participant was not homeless. As a result of the conditions described above, the Authority


                                                 4
incurred program expenses for 33 participants who were at risk of homelessness but not
homeless as defined by the program.

Persons With Disabilities Requirements Not Met
According to 24 CFR 582.5, HUD defines a person with disabilities as an individual who has a
disability that (1) is expected to be of long-continued and indefinite duration, (2) substantially
impedes the ability to live independently, and (3) could be improved by more suitable housing
conditions. This disability may be a physical, mental, or emotional impairment, emphasizing
that the impairment is of long-continued and indefinite duration that substantially impedes the
person’s ability to live independently.

Authority management stated that it used the County to determine whether participants had met
HUD’s definition of persons with disabilities. However, it did not verify the County’s
assessments to ensure that 17 of the 75 reviewed participants met HUD’s definition of disabled
as required by 24 CFR 582.400(a) and its Shelter Plus Care program grant agreements. The
participants’ file documentation did not support their disability. Specifically, none of the
participants’ files contained documentation that identified a disability diagnosed by a treating
and licensed professional. Further, these participants earned income from employment that
allowed for independent living. This situation contradicted one of HUD’s definitions of a person
with disabilities in that the participant’s disability must impair his or her ability to live
independently. Further, none of these participants received a Social Security benefits payment
from the Social Security Administration that would support his or her disability eligibility as
required by 24 CFR 582.301(c)(3).

The Authority’s applications used during the intake process included language certifying that the
participants were able to live independently that contradicted the program requirements. On the
application, County intake personnel were required to certify in a yes or no response, “Has the
applicant demonstrated sufficient psychiatric stability to be able to live independently?”
However, HUD requires that participants have a disability that “substantially impedes the
individual’s ability to live independently.” The Authority, through the County, determined that
the participants had met the disability requirements. This certification language in the
applications regarding the participants’ independent living skills contradicts HUD’s disability
requirements. Thus, the 17 participants reviewed were ineligible for the program.

Participants’ Disabilities Certified by Unlicensed Personnel
As of January 4, 2012, the Authority had used four of its grants, covered by the HEARTH Act
amendment, totaling more than $4.2 million toward having intake staff diagnose and certify
participants’ disabilities as defined in 24 CFR 582.301(c)(1). However, County staff was not
professionally licensed to diagnose and certify participants’ disabilities as required by HUD. As
a result, the Authority provided program funds to participants using unlicensed professional staff
to determine the disability status of the participants.

As shown in appendix D, of 75 participants reviewed, 50 were ineligible for the program, which
equated to $865,890 in ineligible costs. Since we conducted a statistical sample, we statistically
projected the results of our sample to the universe of the Authority’s program expenditures (see


                                                  5
Scope and Methodology section of the audit report). Overall, the Authority spent an average of
$7,288 on each of the 428 participants in the program from October 2010 to September 2014.
As a result, we projected that it spent more than $3.1 million in program funds on participants
who were not eligible for the program.

The Authority Did Not Have Documentation To Support Participants’ Eligibility
The Authority incurred program costs for 8 of the 75 participants reviewed for whom
documentation was missing, and we could not verify their eligibility (see appendix D).

Missing Participants’ Applications
The Authority did not obtain applications for 4 of the 75 participants. It was unclear how
participants met HUD’s definition of homeless in 24 CFR 582.5 and the McKinney-Vento
Homeless Assistance Act, Section 103, without applications in their files. In addition, these
applications would have shown whether the participants had a disability as defined at 24 CFR
582.5. Instead, the Authority documented only applicants’ Social Security benefits to show that
disability requirements were met under HUD rules and requirements. Without these
applications, we could not confirm eligibility of the participants and the related program funds
spent totaling $66,084.

Missing Documentation To Support Program Eligibility
The Authority did not obtain documentation to support the eligibility of an additional 4 of the 75
participants in the program. It did not obtain documentation for three participants to support
whether they met program homeless requirements stated in 24 CFR 582.5 and the McKinney-
Vento Homeless Assistance Act, Section 103. It also did not obtain the required documentation
to support the disability eligibility of one participant in the program as required by 24 CFR
582.5. As a result, the Authority incurred costs of $70,262 for participants for whom it could not
provide documentation to support that they met program homeless ($51,832) or disability
($18,430) eligibility requirements. Overall, it did not obtain the required documentation to
support the eligibility of $136,346 in program funds spent on eight participants.

Conclusion
The Authority did not ensure that participants met the homeless and disability eligibility
requirements of the program. Of 75 participants reviewed, 50 were ineligible for the program.
We could not validate the eligibility of eight participants because of missing documents. This
condition occurred because the Authority relied on the County to determine participants’
eligibility without monitoring the process. The Authority’s internal controls and procedures
outlined program requirements that were inconsistent with HUD requirements for determining
participants’ homeless and disability eligibility. As a result, the Authority spent more than $3.2
million in program funds on ineligible participants and participants who did not have the
required documentation to support their eligibility. Unless the Authority improves its monitoring
of participant eligibility, we estimate that it will spend at least $873,428 next year on ineligible
participants. Further, the Authority’s practices created a risk of not meeting HUD’s goal of
ending homelessness for individuals with disabilities and their families within San Bernardino
County.




                                                 6
Recommendations
We recommend that the Director of the HUD’s Los Angeles Office of Community Planning and
Development require the Authority to

      1A.    Repay HUD $3,119,448 from non-Federal funds for program funds spent on
             ineligible participants.

      1B.    Provide supporting documentation for $136,346 in program funds used for
             participants for whom eligibility could not be determined or repay HUD from
             non-Federal funds (see appendix D).

      1C.    Develop and implement written policies and procedures to ensure that participants
             are eligible for the program and comply with HUD rules and requirements. Also,
             the Authority should ensure that these policies and procedures include the
             monitoring of third-party organizations involved with the program so that
             $873,428 in program funds can be put to better use.




                                              7
Scope and Methodology
We performed our audit work at the Authority’s office in San Bernardino, CA, from October 15,
2014, to February 19, 2015. Our review covered the period October 1, 2010, to September 30,
2014, and was expanded as necessary.

To accomplish our objective, we performed the following:

   •   Reviewed the Authority’s organizational charts;

   •   Reviewed and analyzed the Authority and County’s policies, procedures, and internal
       controls relating to its program;

   •   Reviewed prior audit reports related to the Authority;

   •   Reviewed applicable HUD laws, regulations, notices of funding availability, and other
       program requirements;

   •   Reviewed HUD monitoring reports, annual progress reports, the Authority’s
       administrative plan, and program funding applications and agreements;

   •   Reviewed the Authority’s audited financial statements for fiscal years 2011, 2012, and
       2013;

   •   Interviewed Authority and County personnel familiar with the administration of the
       program; and

   •   Reviewed selected participant files.

We relied on data maintained by the Authority’s accounting software. Specifically, we relied on
the accuracy of data extracted from its database containing participant names and their
corresponding program assistance. We performed a data reliability assessment and determined
that the data were sufficiently reliable for our audit objective. Specifically, we compared the
monthly amount of housing assistance payments in the data with the amount found in each of our
sample participant files that was reported to HUD. The Authority provided a universe of all
participants it served during the period October 1, 2010, through September 30, 2014.

To test whether the participants were eligible for the program, we used the expertise of one of the
Office of Inspector General’s (OIG) statisticians. The statistician determined a universe
consisting of 428 participants, who received more than $5.3 million in housing assistance from
October 2010 to September 2014. From the universe, the statistician provided a statistical
sample of 75 participants to review that totaled more than $1.2 million in program funds. The


                                                 8
sample was randomly selected and tested for error, resulting in no identified errors. We
determined that 50 of the 75 statistically sampled participants were ineligible for program
assistance.

Based on data provided by the Authority, the OIG statistician determined that the average
program expense for 428 participants was $8,348. With a one-sided confidence interval of 95
percent, the statistician deducted for statistical variance to accommodate the uncertainties
inherent in statistical sampling, resulting in an average amount per tenant of $7,288. This
amount, throughout the universe of 428 participants, resulted in more than $3.1 million in
program funds that the Authority spent on ineligible participants (see appendix A).

Further, the statistician determined that the Authority disbursed an estimated average of $444 in
ineligible monthly payments to participants. Using a one-sided confidence interval of 95
percent, the statistician deducted for statistical variance to accommodate the uncertainties
inherent in statistical sampling, which resulted in an average amount of $373 that the Authority
spent on each ineligible participant. The statistician applied this amount to the 195 participants
throughout 1 year and deducted for the margin of error with a one-sided confidence interval of
95 percent. Based on this projection, if the Authority addresses the deficiencies identified in this
report, at least $873,428 in ineligible program costs could be put to better use next year (see
appendix A).

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.




                                                  9
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.

•   Compliance with applicable laws and regulations – Policies and procedures that management
    has implemented to reasonably ensure that program expenses are supported and comply with
    program requirements 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 Deficiency
Based on our review, we believe that the following item is a significant deficiency:

•   The Authority did not provide adequate monitoring and oversight of the administration of its
    program funds to ensure that participants were eligible (finding).




                                                  10
Appendixes

Appendix A
          Schedule of Questioned Costs and Funds To Be Put to Better Use
       Recommendation                                      Funds to be put
                           Ineligible 1/  Unsupported 2/    to better use 3/
           number
               1A            $3,119,448
               1B                                  $136,346
               1C                                                     $873,428

             Totals          $3,119,448            $136,346           $873,428



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 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, if the Authority implements our recommendations, it will ensure that eligible
     participants are provided program services that meet HUD’s objective to reduce
     homelessness of individuals with disabilities and their families in the County of San
     Bernardino. It will no longer spend program funds on ineligible participants who place
     its program at risk of not meeting HUD’s objective. Our estimate of $873,428 reflects
     only the initial year of this benefit (see Scope and Methodology section of the audit
     report). This amount does not include potential offsetting costs incurred by HUD to
     implement our recommendations to strengthen monitoring controls.




                                              11
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 1




Comment 2




                               12
Comment 3




Comment 4




Comment 5
Comment 6




            13
Comment 7




Comment 8




Comment 9




            14
Comment 10


Comment 11




Comment 12




             15
Comment 13




             16
17
Comment 14




             18
Comment 15




             19
Comment 16




             20
Comment 17




Comment 18
Comment 19




             21
22
23
                         OIG Evaluation of Auditee Comments


Comment 1   We agree that the Authority has an extensive portfolio of Housing Choice
            Vouchers and that our review focused on the Authority’s Shelter Plus Care (SPC)
            program. As stated in 24 CFR 582.300(d), the Authority is required to keep and
            make any records associated with program funds available for review. In
            November and December 2014, we made formal requests for 14 and 61
            participant files, respectively. In their responses, the Authority did not
            differentiate to us whether the requested files were in electronic or paper format.
            As a result, we reviewed the paper-based files provided to us. Based on these
            files, we reviewed the participant’s applications, documentation to support their
            homelessness, and social security documentation such as copies of benefit
            payments that would have supported disability. These files did not have detailed
            medical information to show that the Authority ensured disability eligibility
            requirements were met. The Authority stated that privacy acts prohibited it from
            keeping this information in their files. On December 9, 2014, we met with the
            Authority to obtain additional information on the program’s intake process.
            During this meeting, we discussed the program issues identified during the survey
            phase of our review. Among the issues, we brought to the Authority’s attention
            about the lack of documentation, inconsistent notes, and disability assessment by
            non-licensed personnel. See also Comment 3.

            At no time during the audit field work did we preclude the Authority from
            providing additional files or documentation to support the audit objectives. In
            fact, there were ample opportunities for the Authority to provide any additional
            documentation or records. The audit team had discussed the issues during the
            audit fieldwork and at the conclusion of the fieldwork. The Authority did not
            mention to us concerns about the results. In February 2015, we emailed a
            preliminary finding outline that was an informational outline that preceded the
            draft report. In the email, we advised that the information in the outline was open
            for discussion and comment. We stated that the finding outline was subject to
            change, but welcomed any comments. The Authority declined the need to discuss
            it.

Comment 2   We did not dispute the need for this program. In fact, the objective of our audit
            was to ensure that the funds were being used to assist those that the Authority
            described. We strongly disagree with the Authority’s characterization of our audit
            as being dissonant and uninformed. As described in the Scope and Methodology
            section of our report, we conducted about four months of fieldwork and reviewed
            extensive information and interviewed Authority and County personnel familiar
            with the program to fully understand the Authority’s SPC program. We did not
            presume ourselves as program experts; instead we relied on our review of the
            documentation and information provided by the Authority to draw our




                                             24
            conclusions that the Authority did not ensure that participants had met program
            homelessness and disability eligibility requirements.

Comment 3   During the audit fieldwork, we made formal requests for complete file records of
            the 75 statistically sampled participants. At that time the Authority asserted that
            the County maintained its own files, but that the only difference between the files
            was that the County’s participant files included applicable medical assessment
            notes of the participants. The Authority advised that due to the privacy laws; the
            files at the County were not available for our review. As a result, we focused our
            review on participant files that were made available to us at the Authority’s office.
            In our assessment, the Authority files had sufficient information on the
            participants to assess compliance with SPC program requirements. Further, we
            acknowledge that HUD revised the requirements to allow for more flexibility in
            administering the program. We took those revisions into account during our
            review. In addition, we disagree with the Authority’s comment that “most of the
            families came directly from an emergency shelter program thereby conclusively
            establishing their homeless status.” During a January 5, 2015 meeting, the
            Authority management stated that its subrecipient, the County, receives
            participants from contracted external clinics. Further, these referrals are usually
            individuals who have been admitted to a mental health clinic or emergency
            shelter. However, the Authority files do not include information that document
            those participants being in an emergency shelter to support meeting HUD’s
            program requirements. This issue of the Authority maintaining one version of
            participant files, while its subrecipient maintains another version of the file further
            supports our concerns that the Authority did not monitor its program to ensure
            compliance with HUD rules and requirements.

Comment 4   As stated in comments 1 and 3, we requested that the Authority provide us
            complete files of the sampled participants so that we could determine compliance
            with rules and requirements. As the grantee in charge of administering the
            program, HUD requires the Authority to ensure complete records are available for
            review. As such, our review was on the Authority and not its subrecipients, the
            County. Accordingly, Authority management stated that the County determined
            disability eligibility of the participants, not the Authority. It relied on
            documentation from the County to determine eligibility without verification to
            ensure compliance with program rules and requirements. As stated in the report,
            we identified instances unlicensed professionals assessed and certified
            participants’ disability to meet program requirements. This practice occurred as a
            result of the Authority’s reliance on the County performing the work without
            ensuring it was in compliance with HUD rules and requirements.

Comment 5   We disagree. This audit illustrated that the Authority administered its program in
            a manner that raises concerns of funds wasted on ineligible participants that could
            also be characterized as program abuse. Further, as noted in comment 4, we




                                               25
            identified instances where personnel falsely represented themselves as licensed
            professionals, when they were not.

Comment 6   We disagree with the Authority’s assertion. As noted in comment 1, there was
            ongoing communication and dialogue about the information requested and our
            conclusions. As stated in the Scope and Methodology section, we conducted our
            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. In our assessment the evidence obtained during our audit of the
            Authority, provided a reasonable basis for our finding and conclusions. If the
            Authority has additional information it would like to submit, it will certainly have
            that opportunity to provide it to HUD during the audit resolution process after the
            report is issued.

Comment 7   We strongly disagree with the Authority’s accusation of discrimination. Our issue
            is that unlicensed County staff assessed these questioned individuals’
            disability. The participants in question had sources of income from regular
            employment and no disability benefits from the Department of Social
            Security. There was no other evidence to support the participants’ had a disability
            in accordance to HUD rules and requirements. As stated in the report, an
            individual is considered to meet the disability requirement if the disability impairs
            their ability to live an independent life. However, the Authority’s files for these
            participants showed documentation that they were able to live an independent life
            without impairment. As a result, we believe that our conclusions for these
            participants are correct.
Comment 8   As noted in comment 6, our audit work was sufficient and we took into
            consideration everything that the Authority provided to us. Further, as noted in
            comment 1, there was ongoing communication during our audit on the records
            requested, as well as tentative findings and conclusions. At no time, did the
            Authority express disagreement or request to discuss the need to review additional
            files or records with us until our exit conference to discuss the draft report. The
            “repeated requests” that the Authority referred to were all made after our audit
            fieldwork was completed and the discussion draft was sent out and the due date
            established for its written response.

Comment 9   We acknowledged that the Authority had a partnership with the County to assist
            with determining participant eligibility for HUD and non-HUD programs.
            Nevertheless, it was the Authority’s responsibility as the grantee to ensure
            compliance with HUD’s SPC program requirements. We focused our review on
            whether the Authority ensured that participants were specifically eligible as
            defined in HUD program requirements. As noted in the audit, our review of the
            Authority’s files showed that 50 of 75 participants reviewed were ineligible.




                                              26
Comment 10 The Authority’s files reviewed during the audit did not reflect that the participants
           were eligible and there were certifications made at that time as to the eligibility of
           the participants. During the audit resolution, the Authority can provide any
           additional documentation to HUD for consideration.

Comment 11 We disagree with the Authority’s assertion. After a formal request, the Authority
           provided us a memorandum of understanding dated July 1, 2012, which it
           executed with the County to provide services on its behalf using HUD funds.
           However, the memorandum of understanding provided in Attachment A 1 of this
           response was never provided to us during the audit fieldwork. In addition, this
           document dated August 6, 2005, was only for two of the eight grants that we
           reviewed. Section III. C. of the memorandum of understanding dated July 1,
           2012, required that the Authority ensure that homeless assistance funds are
           administered in accordance with the requirements of applicable laws and program
           regulations. 24 CFR 582.400(a) states that HUD will hold the Authority
           responsible for the overall administration of the program, including overseeing
           the County’s handling of the program. Under the grant agreement, it agrees to
           operate the program in accordance with provisions of this part and other
           applicable HUD regulations.

                 We acknowledged the emails in attachment B1, specifically the emails dated
                 December 29, 2014, and January 7, 2015. Initially, we requested participant files
                 from the County. However, meetings with the Authority and the County found
                 that two files existed for each participant. The County maintained a set of files
                 that included medical information needed to assess their disability requirement
                 into the program. Due to issues in obtaining complete participant files, we
                 informed the County that we wanted information about the names of personnel
                 who assessed the eligibility the sampled participants. We did not request access
                 to County participant files to allow us to determine the names of the individuals
                 that assessed sampled participants’ disability. Instead, we attempted to use the
                 State of California’s online database to verify the credentials of personnel
                 performing the assessments of participants.

Comment 12 We disagree. Throughout the review, we kept the Authority management aware of
           the audit status and they were invited to all interviews. On December 18, 2014,
           we met with the County to discuss its responsibilities for the program. At this
           time, Authority management declined to attend. During this meeting, we
           welcomed the County to bring any other personnel responsible for assessing
           participant eligibility requirements. We asked about program oversight and the
           County confirmed that the Authority did not perform formal monitoring of its




1
 We did not include the attachments (A through I) in the report because it was too voluminous; however, they are
available upon request.


                                                         27
records or work. That contradicts the Authority’s assertion in its response that it
oversees the County records.

Throughout the audit, we requested all participant files from the Authority to
complete the audit. The Authority stated that it would provide us the requested
documentation. During the audit, the Authority stated that privacy laws did not
allow for it to access County files that included relevant medical information
needed to determine that disability requirements were met. At one time, the
Authority did have the information in its files; however, it removed the
documentation. This practice resulted in the Authority being dependent on the
County to maintain another set of files that included participant medical
information. Due to these issues with accessing files that the Authority should
have been able to maintain, we did not review the County files. Instead, we
focused our attention on reviewing the County staff that accessed the participants
to determine whether they were licensed to assess disability.

Since we used the State of California’s Board of Behavioral Science and
Department of Consumer Affair database to verify County personnel’s license,
there was no need to obtain information from the County. During the audit, we
made the Authority aware of our concerns about unlicensed County staff
assessing participants under the pretense that they were licensed. The Authority
did not provide us documentation that addressed our reported issue.

We had already reviewed the document that Authority provided in Attachment C
during the audit fieldwork. However, we had concerns about the individual
signing the form as a licensed social worker. A review of the State of California’s
database for licensed professionals in the behavior health field showed that this
individual was not licensed until at least one year after signing the document.
With regard to the use of licensed marriage and family therapists (LMFT), we had
concerns that individuals with this license assessed participants’ physical
disability, not the mental disability as the Authority believes had occurred. Their
examples support our concerns of unlicensed individuals assessing participants’
disabilities. Further, the Authority’s incorrect statement supports our concerns
that it did not monitor the program to ensure that participants were eligible for the
program.

While conducting our review of the Authority, two formal requests were made for
complete file records of all participants sampled. On November 5, 2014, we
requested that the Authority provide us 14 complete files for review during the
survey phase. On December 1, 2014, we made a second request for an additional
61 complete files for review during the audit phase. Authority management never
advised there were additional electronic records. 24 CFR 582.300(d) required the
Authority keep all program files available for review by HUD. During another
meeting with management, we made them aware that the review would be based
on all documents that are maintained by the Authority. As a result, our audit was


                                  28
              dependent on the Authority providing us with all complete files to meet our audit
              objective. The Authority’s failure to provide us with complete files would raise
              concerns that it did not maintain complete documents as required by HUD.

              As stipulated in HUD Handbook 2000.06 Rev-4, Appendix 1, ineligible costs are
              those “questioned because of an alleged violation of a provision of a law,
              regulation, contract, grant, cooperative agreement, or other agreement or
              document governing the expenditure of funds.” As detailed in the audit report,
              we identified reoccurrences where documentation provided to auditors
              contradicted program requirements for both homeless and disability requirements,
              therefore deeming questioned costs ineligible. As a result, our characterization of
              costs as ineligible was correct. Nevertheless, as part of the audit resolution, the
              Authority will have the opportunity to provide documentation to support the
              questioned costs.

Comment 13 The Authority administered eight separate grants and each of those grants were
           subject to 24 CFR 582, Notice of Funding Availabilities for 2007, 2009—2013,
           and the HEARTH ACT, depending on the date of the grant agreement. If
           participants were under a State of California-funded program that provided them
           additional assistance, this information was not in the files provided to us by the
           Authority. As a result, we applied the corresponding requirements previously
           mentioned to determine whether the Authority ensured that eligible participants
           were homeless as defined by HUD.

              We agree that the Authority maintains a memorandum of understanding with the
              County for an unrelated program, Master Leasing Housing Program, a State of
              California-funded program (attachment D). However, the information within the
              files did not provide documentation to show that the emergency shelter housing
              program meets HUD requirements to allow participants to transition to the HUD
              program and meet homelessness requirements. We acknowledge the listing of
              HUD’s definition and requirements for homelessness as stated in attachment E.
              Within this attachment, written documentation or certification is requirement to
              show that the participant would meet program requirements. However, the 33
              files did not have the required documentation that show the Authority ensure that
              the participants in question had met homelessness eligibility. The Authority
              should provide complete documentation during the audit resolution process after
              the report is issued evidencing participants meeting program homelessness
              requirements.

Comment 14 In the same manner as the homelessness requirement, we used the appropriate
           requirements within 24 CFR 582, Notice of Funding Availabilities for 2007,
           2009—2013, and the HEARTH ACT to determine whether the Authority ensured
           that participants met program disability requirements. As a result, we concluded
           that the Authority did not ensure that the 17 participants had met disability




                                               29
              requirements as defined by HUD. Any additional information can be provided to
              HUD during the audit resolution process.

Comment 15 We determined that there were instances of individuals assessing participants’
           disability requirements by unlicensed professionals. In addition, the
           documentation provided in Attachment C further supported the finding that
           unlicensed personnel were assessing participants’ disability. On November 7,
           2013, the individual signed the redacted form as a Master’s in Social Work intern
           or MSWI. However, the State of California Department of Consumer Affair’s
           database system for licensed health professionals showed that this individual was
           not licensed as an associate clinical social worker until December 3, 2014. The
           Authority provided us a listing of individuals who they believed to have been
           licensed professionals that assessed the participants’ disability. A comparison of
           the names to the State’s database system identified some individuals licensed as
           marriage and family therapist assessing physical disabilities of participants to
           determine eligibility into the program. These instances could place the Authority
           at risk due to incorrect assessments by those individuals not specialized in the
           area of the participants’ needs.

Comment 16 As stated in the previous comments, we requested that the Authority provide us
           complete participants’ files. Nevertheless, the Authority will have the opportunity
           during the audit resolution phase to provide additional documentation to HUD to
           address the audit recommendations.

Comment 17 We disagree. The Authority did not provide us the memorandum of
           understanding included in Attachment A until its response to this audit. This
           document signed on July 11, 2005, covered only two of the eight program grants
           that we reviewed during the audit. The memorandum of understanding provided
           during the audit was dated July, 1, 2012, and indicated that the County would
           determine participant eligibility for the program. It further stated that the
           Authority was responsible for complying with program rules and requirements.
           The procedures, revised on August 25, 2011, included in Attachment G are
           admission procedures for personnel to follow when processing participants for the
           program. Attachment H is the Authority’s review procedures for personnel to
           follow to ensure information is entered into the appropriate computer system.
           Neither of the documents were formal monitoring policies and procedures that
           would have allowed the Authority to ensure eligibility compliance with program
           rules and requirements. At the time of our review, we did not identify any formal
           monitoring policies and procedures in place at the time of audit. As a result, we
           believe that the recommendation is appropriate to ensure that it has monitoring
           policies and procedures in place to ensure compliance with HUD rules and
           requirements. However, the Authority will have additional opportunities to
           address this with HUD during the audit resolution process.




                                              30
Comment 18 We agree that HUD monitoring results were positive with no findings. However,
           HUD reviewed three of the eights grants in March 2011. Since the 2011 review,
           HUD has not reviewed the program to determine whether there were findings.
           Given the time that has occurred since the 2011 review, it would be inaccurate to
           conclude that the program still operated without any issues. As a result, we
           conducted a review of all eight grants within the program to determine if there
           were issues that would raise concerns as to whether the Authority was in
           compliance with program rules and requirements.

Comment 19 We disagree with the Authority’s opinion about the manner in which we
           conducted the review and reached our conclusion. In addition, HUD’s 2011
           monitoring of three grants under the program may have resulted in no findings,
           but our 2015 review of all eight grants identified issues that the Authority must
           address to ensure compliance. It will have the opportunity to resolve those issues
           identified in this report by providing the required documentation to show that it
           ensured participants were eligible for the program. Based on the documentation
           provided to HUD, we may adjust the questioned costs accordingly.




                                              31
Appendix C
                                             Criteria
The following are sections of 24 CFR Part 582, the McKinney-Vento Homeless Assistance Act,
the notice of funding availability, and agreements.

24 CFR 582.5, Definitions, effective April 1, 2008
Homeless or homeless individual has the meaning given in section 103 of the McKinney Act (42
U.S.C. [United States Code] 11302).

Person with disabilities means a household composed of one or more persons at least one of
whom is an adult who has a disability.

(1) A person shall be considered to have a disability if such person has a physical, mental, or
    emotional impairment which is expected to be of long-continued and indefinite duration;
    substantially impedes his or her ability to live independently; and is of such a nature that such
    ability could be improved by more suitable housing conditions.

(3) Notwithstanding the preceding provisions of this definition, the term person with disabilities
    includes, except in the case of the SRO [single room occupancy] component, two or more
    persons with disabilities living together, one or more such persons living with another person
    who is determined to be important to their care or well-being, and the surviving member or
    members of any household described in the first sentence of this definition who were living,
    in a unit assisted under this part, with the deceased member of the household at the time of
    his or her death. (In any event, with respect to the surviving member or members of a
    household, the right to rental assistance under this part will terminate at the end of the grant
    period under which the deceased member was a participant.)

24 CFR 582.300, General Operations, effective April 1, 2008
(d) Records and reports. (1) Each recipient must keep any records and, within the timeframe
required, make any reports (including those pertaining to race, ethnicity, gender, and disability
status data) that HUD may require.
24 CFR 582.400, Grant Agreement, effective April 1, 2008
(a) General. The grant agreement will be between HUD and the recipient. HUD will hold the
recipient responsible for the overall administration of the program, including overseeing any
subrecipients or contractors. Under the grant agreement, the recipient must agree to operate the
program in accordance with the provisions of this part and other applicable HUD regulations.
McKinney-Vento Homeless Assistance Act, Section 103, General definition of homeless
individual, effective May 20, 2009
(a) In general
       For purposes of this chapter, the terms ‘‘homeless’’, ‘‘homeless individual’’, and
       ‘‘homeless person’’ means—



                                                  32
(1) an individual or family who lacks a fixed, regular, and adequate nighttime residence;

(2) an individual or family with a primary nighttime residence that is a public or private
    place not designed for or ordinarily used as a regular sleeping accommodation for
    human beings, including a car, park, abandoned building, bus or train station, airport,
    or camping ground;

(3) an individual or family living in a supervised publicly or privately operated shelter
    designated to provide temporary living arrangements (including hotels and motels
    paid for by Federal, State, or local government programs for low-income individuals
    or by charitable organizations, congregate shelters, and transitional housing);

(4) an individual who resided in a shelter or place not meant for human habitation and
    who is exiting an institution where he or she temporarily resided;
(5) an individual or family who—
       (A) will imminently lose their housing, including housing they own, rent, or live
          in without paying rent, are sharing with others, and rooms in hotels or motels
          not paid for by Federal, State, or local government programs for low-income
          individuals or by charitable organizations, as evidenced by—
               (i) a court order resulting from an eviction action that notifies the
                   individual or family that they must leave within 14 days;
               (ii) the individual or family having a primary nighttime residence that is a
                    room in a hotel or motel and where they lack the resources necessary
                    to reside there for more than 14 days; or
               (iii) credible evidence indicating that the owner or renter of the housing
                     will not allow the individual or family to stay for more than 14 days,
                     and any oral statement from an individual or family seeking homeless
                     assistance that is found to be credible shall be considered credible
                     evidence for purposes of this clause;
       (B) has no subsequent residence identified; and
       (C) lacks the resources or support networks needed to obtain other permanent
           housing
(6) unaccompanied youth and homeless families with children and youth defined as
    homeless under other Federal statutes who—
       (A) have experienced a long term period without living independently in
          permanent housing,
       (B) have experienced persistent instability as measured by frequent moves over
           such period, and


                                          33
               (C) can be expected to continue in such status for an extended period of time
                   because of chronic disabilities, chronic physical health or mental health
                   conditions, substance addiction, histories of domestic violence or childhood
                   abuse, the presence of a child or youth with a disability, or multiple barriers to
                   employment.
Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act, 24 CFR
582.5, Definitions, effective January 4, 2012
Homeless means:
(1) An individual or family who lacks a fixed, regular, and adequate nighttime residence,
    meaning:
   (i) An individual or family with a primary nighttime residence that is a public or private place
       not designed for or ordinarily used as a regular sleeping accommodation for human
       beings, including a car, park, abandoned building, bus or train station, airport, or camping
       ground;
   (ii) An individual or family living in a supervised publicly or privately operated shelter
        designated to provide temporary living arrangements (including congregate shelters,
        transitional housing, and hotels and motels paid for by charitable organizations or by
        federal, state, or local government programs for low income individuals); or
   (iii) An individual who is exiting an institution where he or she resided for 90 days or less
         and who resided in an emergency shelter or place not meant for human habitation
         immediately before entering that institution;
(2) An individual or family who will imminently lose their primary nighttime residence,
    provided that:
      (i) The primary nighttime residence will be lost within 14 days of the date of application
          for homeless assistance;
      (ii) No subsequent residence has been identified; and
      (iii) The individual or family lacks the resources or support networks, e.g., family, friends,
            faith-based or other social networks, needed to obtain other permanent housing;
Person with disabilities means a household composed of one or more persons at least one of
whom is an adult who has a disability.
(1) A person shall be considered to have a disability if he or she has a disability that:
       (i) Is expected to be long-continuing or of indefinite duration;
       (ii) Substantially impedes the individual’s ability to live independently;
       (iii) Could be improved by the provision of more suitable housing conditions; and



                                                   34
       (iv) Is a physical, mental, or emotional impairment, including an impairment caused by
           alcohol or drug abuse, posttraumatic stress disorder, or brain injury.
HEARTH Act, 24 CFR 582.301, Recordkeeping, effective January 4, 2012
(b) Homeless status. The recipient must maintain and follow written intake procedures to ensure
    compliance with the homeless definition in § 582.5. The procedures must require
    documentation at intake of the evidence relied upon to establish and verify homeless status.
    The procedures must establish the order of priority for obtaining evidence as third-party
    documentation first, intake worker observations second, and certification from the person
    seeking assistance third. However, lack of thirdparty [sic] documentation must not prevent
    an individual or family from being immediately admitted to emergency shelter, receiving
    street outreach services, or being immediately admitted to shelter or receiving services
    provided by a victim service provider, as defined in section 401(32) of the McKinney-Vento
    Homeless Assistance Act, as amended by the HEARTH Act. Records contained in an HMIS
    [homeless management information system] or comparable database used by victim service
    or legal service providers are acceptable evidence of third-party documentation and intake
    worker observations if the HMIS retains an auditable history of all entries, including the
    person who entered the data, the date of entry, and the change made; and if the HMIS
    prevents overrides or changes of the dates entries are made.
(c) Disability. Each recipient of assistance under this part must maintain and follow written
    intake procedures to ensure that the assistance benefits persons with disabilities, as defined in
    § 582.5. In addition to the documentation required under paragraph (b), the procedures must
    require documentation at intake of the evidence relied upon to establish and verify the
    disability of the person applying for homeless assistance. The recipient must keep these
    records for 5 years after the end of the grant term. Acceptable evidence of the disability
    includes:
       (1) Written verification of the disability from a professional licensed by the state to
       diagnose and treat the disability and his or her certification that the disability is expected
       to be long-continuing or of indefinite duration and substantially impedes the individual’s
       ability to live independently;
       (2) Written verification from the Social Security Administration;
       (3) The receipt of a disability check (e.g., Social Security Disability Insurance check or
       Veteran Disability Compensation);
       (4) Intake staff-recorded observation of disability that, no later than 45 days of the
       application for assistance, is confirmed and accompanied by evidence in paragraph (c)(1),
       (2), (3), or (4) of this section; or
       (5) Other documentation approved by HUD.




                                                  35
Notice of Funding Availability for the Continuum of Care Homeless Assistance Program for
Fiscal Year 2009
1.A.4.e. Chronically Homeless Person. An unaccompanied homeless individual with a disabling
condition who has either been continuously homeless for a year or more OR has had at least four
(4) episodes of homelessness in the past three (3) years. A disabling condition is defined as:

       (1) a disability as defined in Section 223 of the Social Security Act;
       (2) a physical, mental, or emotional impairment which is expected to be of long-
           continued and indefinite duration, substantially impedes an individual’s ability to live
           independently, and of such a nature that the disability could be improved by more
           suitable conditions;
       (3) a developmental disability as defined in Section 102 of the Developmental
           Disabilities Assistance and Bill of Rights Act;
       (4) the disease of acquired immunodeficiency syndrome or any conditions arising from
           the etiological agency for acquired immunodeficiency syndrome; or
       (5) a diagnosable substance abuse disorder. The term “homeless” in this case means a
           person sleeping in a place not meant for human habitation (e.g., living on the streets),
           in an emergency homeless shelter, or in a Safe Haven as defined by HUD.
Shelter Plus Care Grant Agreements Between the Housing Authority of the County of San
Bernardino and HUD
“Recipient agrees to conduct an ongoing assessment of the rental assistance and supportive
services required by the participants in the program; to be responsible for the overall
administration of this grant, including overseeing any subrecipients, contractors and
subcontractors; and to comply with such other terms and conditions, including record keeping
and reports (which include racial and ethnic data on participants for program monitoring and
evaluation purposes), as the Secretary may establish for purposes of carrying out the program in
an effective and efficient manner.”
“More specifically, Recipient shall not change sponsor or population to be served, or make any
other changes inconsistent with the Application, without prior approval of HUD.”




                                                 36
Appendix D
                       Summary of Review of Participant Eligibility
                        Program eligibility                    Supported eligibility
          Program
                           (yes or no)                             (yes or no)
         funds spent                             Ineligible                             Unsupported
Sample
             on                                   amount                                  amount
         participant   Homeless    Disability                 Homeless     Disability

                       Unable to   Unable to     Unable to
  1        $6,765                                                No           No          $6,765
                       determine   determine     determine
   2       $6,560         Yes         No           $6,560       Yes           No            $0
   3       $2,270         No          Yes          $2,270       No            Yes           $0
   4       $5,830         Yes         No           $5,830       Yes           No            $0
   5       $6,787         Yes         Yes            $0         Yes           Yes           $0
   6       $6,600         Yes         Yes            $0         Yes           Yes           $0
   7       $8,772         Yes         No           $8,772       Yes           No            $0
   8       $7,126         Yes         Yes            $0         Yes           Yes           $0
   9       $9,318         No          No           $9,318       No            No            $0
  10       $9,670         No          No           $9,670       No            No            $0
  11       $7,188         No          Yes          $7,188       No            Yes           $0
  12       $8,075         No          Yes          $8,075       No            Yes           $0
  13       $8,820         Yes         Yes            $0         Yes           Yes           $0
  14       $8,921         No          Yes          $8,921       No            Yes           $0
  15       $8,244         No          Yes          $8,244       No            Yes           $0
  16      $10,758         Yes         No          $10,758       Yes           No            $0
  17      $11,196         No          Yes         $11,196       No            Yes           $0
  18       $9,972         Yes         Yes            $0         Yes           Yes           $0
                       Unable to   Unable to     Unable to
  19      $12,088                                                No           No          $12,088
                       determine   determine     determine
  20      $12,971         Yes         No          $12,971       Yes           No            $0
  21      $10,877         No          Yes         $10,877       No            Yes           $0
  22      $10,188         No          Yes         $10,188       No            Yes           $0
  23      $13,538         No          Yes         $13,538       No            Yes           $0
  24      $10,324         Yes         Yes            $0         Yes           Yes           $0
                       Unable to                 Unable to
  25      $10,080                     Yes                        No           Yes         $10,080
                       determine                 determine
                       Unable to                 Unable to
  26      $13,880                     Yes                        No           Yes         $13,880
                       determine                 determine
  27      $10,062         Yes         No          $10,062       Yes           No            $0
  28      $12,957         Yes         Yes            $0         Yes           Yes           $0
  29      $14,556         No          Yes         $14,556       No            Yes           $0
  30      $15,396         No          No          $15,396       No            No            $0



                                                37
                        Program eligibility                    Supported eligibility
          Program
                           (yes or no)                             (yes or no)
         funds spent                             Ineligible                             Unsupported
Sample
             on                                   amount                                  amount
         participant   Homeless    Disability                 Homeless     Disability

  31      $17,083        Yes          Yes            $0         Yes           Yes           $0
  32      $16,209        No           Yes         $16,209       No            Yes           $0
  33      $19,756        Yes          No          $19,756       Yes           No            $0
                                   Unable to     Unable to
  34      $18,430        Yes                                    Yes           No          $18,430
                                   determine     determine
  35      $18,420         No          Yes         $18,420       No            Yes           $0
  36      $17,608         Yes         No          $17,608       Yes           No            $0
  37      $19,520         No          Yes         $19,520       No            Yes           $0
  38      $22,831         Yes         Yes            $0         Yes           Yes           $0
  39      $22,434         Yes         Yes            $0         Yes           Yes           $0
  40      $21,140         No          Yes         $21,140       No            Yes           $0
  41      $22,920         No          Yes         $22,920       No            Yes           $0
  42      $22,760         Yes         Yes            $0         Yes           Yes           $0
  43      $20,556         No          Yes         $20,556       No            Yes           $0
                       Unable to   Unable to     Unable to
  44      $22,080                                                No           No          $22,080
                       determine   determine     determine
  45      $26,165         No          Yes         $26,165       No            Yes           $0
  46      $23,646         Yes         No          $23,646       Yes           No            $0
                       Unable to   Unable to     Unable to
  47      $25,151                                                No           No          $25,151
                       determine   determine     determine
  48      $24,038         No          Yes         $24,038       No            Yes           $0
  49      $26,341         No          Yes         $26,341       No            Yes           $0
  50      $25,668         Yes         No          $25,668       Yes           No            $0
  51      $25,432         No          Yes         $25,432       No            Yes           $0
  52      $26,103         Yes         Yes            $0         Yes           Yes           $0
  53      $27,519         No          Yes         $27,519       No            Yes           $0
  54      $27,429         No          Yes         $27,429       No            Yes           $0
  55      $29,556         Yes         Yes            $0         Yes           Yes           $0
                       Unable to                 Unable to
  56      $27,872                     Yes                        No           Yes         $27,872
                       determine                 determine
  57      $31,227         Yes         Yes            $0         Yes           Yes           $0
  58      $29,896         No          Yes         $29,896       No            Yes           $0
  59      $30,972         Yes         Yes            $0         Yes           Yes           $0
  60      $31,541         No          Yes         $31,541       No            Yes           $0
  61      $31,466         No          Yes         $31,466       No            Yes           $0
  62       $1,727         Yes         No           $1,727       Yes           No            $0
  63       $8,731         No          Yes          $8,731       No            Yes           $0


                                                38
                        Program eligibility                     Supported eligibility
          Program
                           (yes or no)                              (yes or no)
         funds spent                             Ineligible                              Unsupported
Sample
             on                                   amount                                   amount
         participant   Homeless    Disability                  Homeless     Disability

  64       $9,728        Yes          Yes              $0        Yes           Yes           $0
  65      $14,317        No           Yes            $14,317     No            Yes           $0
  66      $13,625        No           Yes            $13,625     No            Yes           $0
  67      $11,968        Yes          Yes              $0        Yes           Yes           $0
  68      $15,412        No           Yes            $15,412     No            Yes           $0
  69      $15,963        No           Yes            $15,963     No            Yes           $0
  70      $18,488        Yes          No             $18,488     Yes           No            $0
  71      $23,469        No           Yes            $23,469     No            Yes           $0
  72      $24,671        Yes          No             $24,671     Yes           No            $0
  73      $27,456        No           Yes            $27,456     No            Yes           $0
  74      $30,616        Yes          No             $30,616     Yes           No            $0
  75      $31,755        No           Yes            $31,755     No            Yes           $0
Totals   $1,289,484                              $865,890                                 $136,346




                                                39