oversight

The Richmond Redevelopment and Housing Authority, Richmond, VA, Did Not Always Charge Eligible and Reasonable Central Office Cost Center Fees

Published by the Department of Housing and Urban Development, Office of Inspector General on 2016-08-17.

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

      Richmond Redevelopment and
     Housing Authority, Richmond, VA
                   Central Office Cost Center Fees




Office of Audit, Region 3           Audit Report Number: 2016-PH-1005
Philadelphia, PA                                       August 17, 2016
To:            Catherine D. Lamberg, Director, Office of Public Housing, Richmond Field
               Office, 3FPH
               //signed//
From:          David E. Kasperowicz, Regional Inspector General for Audit, Philadelphia
               Region, 3AGA
Subject:       The Richmond Redevelopment and Housing Authority, Richmond, VA, Did Not
               Always Charge Eligible and Reasonable Central Office Cost Center Fees




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 Richmond Redevelopment and Housing
Authority’s central office cost center fees.
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
215-430-6734.
                      Audit Report Number: 2016-PH-1005
                      Date: August 17, 2016

                      The Richmond Redevelopment and Housing Authority, Richmond, VA, Did
                      Not Always Charge Eligible and Reasonable Central Office Cost Center Fees




Highlights

What We Audited and Why
We audited the fees that the Richmond Redevelopment and Housing Authority charged to its
U.S. Department of Housing and Urban Development (HUD) housing programs for central
office cost center services based on issues identified during our prior audit of the Authority. 1
Our audit objective was to determine whether the Authority charged fees to its HUD housing
programs for central office cost center services that were eligible, reasonable, and supported in
accordance with applicable HUD requirements.

What We Found
The Authority did not always charge fees to its HUD housing programs for central office cost
center services that were eligible and reasonable in accordance with HUD requirements.
Specifically, it charged HUD funds (1) $507,800 for an information technology fee that was
duplicative and (2) $5 million based on an hourly maintenance fee rate that was unreasonable for
the services provided. It also made ineligible transfers of HUD funds to its central office cost
center. These conditions occurred because the Authority lacked oversight and controls. As a
result, the Authority improperly used $507,800 in HUD funds for ineligible expenses and could
not show that $5 million in fees paid with HUD funds was reasonable for the services provided.

What We Recommend
We recommend that HUD require the Authority to (1) reimburse its public housing projects
$507,800 from non-Federal funds for the ineligible duplicative information technology fee, (2)
provide documentation to show that the hourly maintenance fees totaling $5 million were
reasonable for the services provided or reimburse its public housing projects from non-Federal
funds for any amount that it cannot support, and (3) continue its efforts and develop and
implement procedures and controls to improve its operations.




1
    Audit Report 2015-PH-1008, The Richmond Redevelopment and Housing Authority, Richmond, VA, Did Not
    Comply With HUD Requirements When Procuring Services, issued September 30, 2015
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................5
         Finding: The Authority Did Not Always Charge Fees to Its HUD Housing
         Programs for Central Office Cost Center Services That Were Eligible and
         Reasonable in Accordance With HUD Requirements ................................................... 5

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

Internal Controls ......................................................................................................9

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

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




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Background and Objective
The Richmond Redevelopment and Housing Authority was established in 1940. The Authority’s
mission is to be the catalyst for quality affordable housing and community revitalization for the
City of Richmond, VA. The Authority is governed by a board of commissioners consisting of
nine members appointed by the city council. The board appoints a chief executive officer to
manage the day-to-day operations of the Authority. In January 2015, the board announced the
resignation of its chief executive officer and selection of a new chief executive officer. The
Authority is located at 901 Chamberlayne Parkway in Richmond, VA.

The Authority is the largest public housing agency in Virginia, serving nearly 10,000 residents.
It manages more than 4,000 units under its public housing program. In fiscal year 2015, the
Authority received $18.2 million in public housing operating subsidies and $6.6 million in public
housing capital funds. The U.S. Department of Housing and Urban Development (HUD)
provides operating funds annually to public housing agencies for the operation and management
of public housing. It provides capital funds annually to public housing agencies for the
development, financing, and modernization of public housing developments and for management
improvements.

In 2005, HUD required public housing agencies with more than 250 units to convert to asset
management and establish a central office cost center. The cost center generates revenue by
using a fee-for-service approach and engaging in business activities. In October 2007, the
Authority established its cost center. During the period October 2012 to September 2015, the
Authority’s cost center generated revenue totaling more than $24.2 million by charging the
following 11 fees to its housing programs.


            No.                         Fees                           Amount

             1.   Property management                                  $7,212,437
             2.   Maintenance                                           4,927,176
             3.   Capital management                                    2,458,087
             4.   Resident services                                     2,158,148
             5.   Call center                                           1,788,569
             6.   Tenant selection                                      1,439,134
             7.   Asset management                                      1,237,920
             8.   Housing Choice Voucher program management             1,022,595
             9.   Bookkeeping                                             946,770
            10.   Public safety                                           538,246
            11.   Information technology                                  507,800
                  Total                                                24,236,882




                                                3
Our objective was to determine whether the Authority charged fees to its HUD housing programs
for central office cost center services that were eligible, reasonable, and supported in accordance
with applicable HUD requirements.




                                                 4
Results of Audit

Finding: The Authority Did Not Always Charge Fees to Its HUD
Housing Programs for Central Office Cost Center Services That
Were Eligible and Reasonable in Accordance With HUD
Requirements
The Authority did not always charge fees to its HUD housing programs for central office cost
center services that were eligible and reasonable in accordance with HUD requirements.
Specifically, it charged HUD funds (1) $507,800 for an information technology fee that was
duplicative and (2) $5 million based on an hourly maintenance fee rate that was unreasonable for
the services provided. It also made ineligible transfers of HUD funds to its central office cost
center. These conditions occurred because the Authority lacked oversight and controls. As a
result, the Authority improperly used $507,800 in HUD funds for ineligible expenses and could
not show that $5 million in fees paid with HUD funds was reasonable for the service provided.

The Authority’s Information Technology Fee Was Duplicative
The Authority improperly charged its public housing projects $507,800 for an information
technology fee that was duplicative. Regulations at 24 CFR (Code of Federal Regulations)
990.280(d) required the Authority to charge each project using a fee-for-service approach when
it chose to centralize functions that directly supported a project. It was also required to charge
each project for the actual services received and only to the extent that such amounts were
reasonable. During fiscal years 2013 and 2014, the Authority charged its public housing projects
an information technology fee for expenses related to providing and supporting computers used
by the public housing projects. However, it also charged the same expenses as a component of
the call center fee. This condition occurred because the Authority lacked oversight and control
to prevent it from charging duplicative central office cost center fees. As a result, the
Authority’s use of $507,800 in public housing funds was ineligible because it charged HUD
funds for a duplicative information technology fee. In September 2015, the Authority reviewed
all financial operations, recognized that the information technology fee was duplicative, and
stopped charging the fee.

The Authority Charged an Unreasonable Maintenance Fee Rate
The Authority charged HUD funds $5 million based on an hourly maintenance fee rate that was
unreasonable for the services provided. Regulations at 24 CFR 990.280(d) required the
Authority to charge each project for the actual services received and only to the extent that such
amounts were reasonable. The supplement to HUD’s Financial Management Handbook 7475.1,
REV, CHG-1, also required the Authority to document how it determined that the fee was
reasonable. It charged a $95 per hour rate for all maintenance services provided to its housing
programs regardless of the type of services. These services ranged from heating, ventilation, and
air conditioning work to general labor like moving furniture and trash pickup. To determine the
hourly rate, the Authority obtained hourly rate quotes from three different vendors in the local


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area for each of the following services: heating, ventilation, and air conditioning; plumbing; and
electrical work. It took the average of all the quotes to establish the $95 per hour rate. Clearly,
the $95 per hour rate for general labor services appeared to be excessive, and information
contained in RSMeans 2 suggests that the $95 per hour rate for heating, ventilation, and air
conditioning work may have been excessive as well. This condition occurred because the
Authority lacked controls to ensure that the maintenance fee it charged was reasonable. As a
result, it could not show that $5 million in fees paid with HUD funds was reasonable for the
service provided.

During the audit, the Authority began to address the reasonableness of the $5 million in
maintenance fees that it charged to HUD funds during the audit period. The Authority
established a fee schedule based on RSMeans cost data indexed for the local area and planned to
apply those rates to all work orders it used to charge the $5 million to HUD funds to determine
how much of the $5 million it charged was reasonable. As of June 2016, the Authority had not
completed this process. Also, for future maintenance services, the Authority informed us that it
planned to use its new fee schedule and update the rates annually to reflect RSMeans rate
changes.

The Authority Made Ineligible Transfers of HUD Funds
The Authority made ineligible transfers of HUD funds from its public housing project accounts
to its central office cost center to cover expenses not associated with the projects. Regulations at
24 CFR 990.280(b)(4) stated that project-specific operating expenses included but were not
limited to direct administrative cost, utilities costs, maintenance costs, tenant services, protective
services, general expenses, nonroutine or capital expenses, and other HUD-identified costs that
were project specific for management purposes. The Authority made the transfers from HUD
funds monthly to cover the budget shortfalls of its cost center. During our prior audit of the
Authority, 3 its general ledger showed a balance due to its public housing projects from the
central office cost center beginning with fiscal year 2012. This general ledger account had a
balance of $6.7 million as of September 2015. The Authority stated that there were no loan
agreements or terms for repayment supporting the transfers. This condition occurred because the
Authority lacked oversight and control to prevent it from making improper transfers of funds
between accounts. As a result, the Authority’s use of as much as $6.7 million in public housing
funds was ineligible because it improperly transferred the funds to pay for expenses not
associated with the operation of its public housing units. In September 2015, the Authority
stopped its improper practice of transferring public housing project funds to its central office cost
center for expenses unrelated to the operation of the projects.

The fiscal year 2014 report by the Authority’s independent auditors disclosed that the Authority
used $4.9 million in public housing operating funds to pay for salaries and other vendor payables
on behalf of the cost center. The report contained a recommendation for the Authority to work
with HUD to determine the full extent of any unallowable expenditures and establish a

2
    RSMeans is North America’s leading supplier of construction cost information, to include facilities maintenance
    and repair cost data, which is indexed by locality. RSMeans is recognized by HUD as an acceptable index for
    estimating facilities maintenance and repair costs.
3
    See footnote 1.


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repayment agreement if necessary. In July 2016, the Authority entered into a repayment
agreement after HUD determined that it needed to repay $6.1 million for unallowable
expenditures that resulted from its ineligible transfers of HUD funds.

The Authority Received Technical Assistance To Improve Its Operations
In September 2015, the Authority began receiving technical assistance from a HUD-funded
contractor to improve its operations. The assistance included reviewing and updating policies
and procedures for the administration of all HUD programs. The assistance also included
training on various topics, such as the budget planning process, accounting procedures, and
internal controls. The Authority was scheduled to receive technical assistance from the
contractor through September 2016.

Conclusion
The Authority did not always charge fees to its HUD housing programs for central office cost
center services that were eligible and reasonable in accordance with HUD requirements. This
condition occurred because the Authority lacked oversight and controls to prevent it from (1)
charging duplicative central office cost center fees, (2) charging an unreasonable maintenance
fee, and (3) making improper transfers of funds between accounts. As a result, the Authority
improperly used $507,800 in HUD funds for ineligible expenses and could not show that $5
million in fees paid with HUD funds was reasonable for the service provided. To address these
and other issues, HUD hired a contractor in September 2015 to provide technical assistance to
the Authority.

Recommendations
We recommend that the Director of HUD’s Richmond Office of Public Housing require the
Authority to

       1A.    Reimburse its public housing projects $507,800 from non-Federal funds related to
              the ineligible duplication of the information technology fee.

       1B.    Provide documentation to show that fees it charged for maintenance services
              totaling $4,927,176 were reasonable or reimburse its public housing projects from
              non-Federal funds for any amount that it cannot support.

       1C.    Continue its efforts and develop and implement controls to prevent the
              duplication of central office cost center fees.

       1D.    Continue its efforts and develop and implement controls to ensure that
              maintenance fees are reasonable.

       1E.    Continue its efforts and develop and implement procedures to prevent it from
              making improper transfers of funds between accounts.




                                                7
Scope and Methodology
We conducted the audit from October 2015 through June 2016 at the Authority’s office located
at 901 Chamberlayne Parkway, Richmond, VA, and our office located in Richmond, VA. The
audit covered the period October 2012 through September 2015.

To accomplish our objective, we reviewed

   •   Relevant background information;
   •   Applicable regulations, HUD handbooks, and the Authority’s policies and procedures;
   •   The Authority’s fiscal years 2013 and 2014 audited financial statements;
   •   RSMeans labor rates for calendar years 2011 through 2015; and
   •   Accounting and housing unit records provided by the Authority to support fees charged
       to its HUD housing programs.

We conducted interviews with responsible employees of the Authority and HUD staff located in
Richmond, VA.

To achieve our audit objective, we relied in part on the Authority’s computer-processed data.
We used the data to review journal vouchers and occupancy reports the Authority used to
support the fees it charged to its HUD housing programs. Although we did not perform a
detailed assessment of the reliability of the data, we did perform limited testing and found the
data to be adequate for our purposes.

During the audit period, the Authority charged the following 11 fees to its HUD housing
programs: (1) property management, (2) bookkeeping, (3) asset management, (4) Housing
Choice Voucher program management, (5) capital management, (6) maintenance, (7) call center,
(8) information technology, (9) resident services, (10) tenant selection, and (11) public safety.
We reviewed monthly journal entries and supporting documentation for the audit period of
October 2012 to September 2015 to determine whether the fees charged were eligible,
reasonable, and supported in accordance with HUD and Federal requirements. We reviewed 100
percent of the fees the Authority charged during the audit period. Therefore, we did not need to
draw a sample or project our audit results.

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.




                                                 8
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:

•   Compliance with laws and regulations – Policies and procedures that management has
    implemented to reasonably ensure that the use of resources is consistent with laws and
    regulations.
We assessed the relevant controls identified above.
A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, the
reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.

Significant Deficiency
Based on our review, we believe that the following item is a significant deficiency:

•   The Authority lacked oversight and controls to prevent it from (1) charging duplicative
    central office cost center fees, (2) charging an unreasonable maintenance fee, and (3) making
    improper transfers of funds between accounts.




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Appendixes

Appendix A


                          Schedule of Questioned Costs
               Recommendation
                                 Ineligible 1/     Unsupported 2/
                   number

                       1A              $507,800
                       1B                                   $4,927,176


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.




                                              10
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 1




                               11
             Auditee Comments and OIG’s Evaluation




Ref to OIG    Auditee Comments
Evaluation




Comment 2




Comment 3
Comment 3




Comment 3


Comment 4




                               12
                         OIG Evaluation of Auditee Comments


Comment 1   The Authority stated that it will work with the Director of HUD’s Richmond
            Office of Public Housing to execute reasonable terms for the repayment of the
            ineligible duplication of the information technology fee. These actions meet the
            intent of our recommendation. As part of the audit resolution process, HUD will
            need to execute a repayment agreement with the Authority to reimburse its public
            housing projects $507,800 from non-Federal funds.

Comment 2   The Authority stated that it was compiling documentation for the Director of
            HUD’s Richmond Office of Public Housing to confirm that fees charged for
            maintenance services totaling approximately $5 million were reasonable. The
            Authority also stated that it would reimburse its public housing projects with non-
            Federal funds for any amount that it cannot support. These actions meet the intent
            of our recommendation. As part of the audit resolution process, HUD will need to
            determine whether the documentation supports the fees charged or direct the
            Authority to reimburse its public housing projects from non-Federal funds for any
            amount that it cannot support.

Comment 3   The Authority stated that it will continue its efforts to develop and implement (1)
            controls to prevent the duplication of central office cost center fees and ensure
            that maintenance fees are reasonable, and (2) procedures to prohibit budget
            deficits and prevent ineligible transfers of funds between accounts. These actions
            meet the intent of our recommendations. As part of the audit resolution process,
            the Authority will need to demonstrate to HUD that it has developed and
            implemented these controls and procedures.

Comment 4   The Authority stated that it had executed a repayment agreement with HUD
            providing for the reimbursement of ineligible transfers of public housing
            operating funds to the central office cost center. On July 14, 2016, we obtained
            from HUD a copy of the executed repayment agreement that was dated July, 6,
            2016. The repayment agreement was for $6.1 million, which is the amount that
            HUD determined was unallowable after reviewing documentation provided by the
            Authority. Accordingly, we updated the final audit report and removed
            recommendation 1F.




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