oversight

The Adams County Housing Authority, Gettysburg, PA, Did Not Administer Its Housing Choice Voucher Program According to HUD Requirements

Published by the Department of Housing and Urban Development, Office of Inspector General on 2018-09-19.

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

     Adams County Housing Authority,
            Gettysburg, PA
                  Housing Choice Voucher Program




Office of Audit, Region 3          Audit Report Number: 2018-PH-1005
Philadelphia, PA                                   September 19, 2018
To:            Monica Hawkins, Director, Office of Public Housing, Pennsylvania State Office,
               3APH
                //signed//
From:          David E. Kasperowicz, Regional Inspector General for Audit, Philadelphia
               Region, 3AGA
Subject:       The Adams County Housing Authority, Gettysburg, PA, Did Not Administer Its
               Housing Choice Voucher Program According to HUD Requirements




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 Adams County Housing Authority’s Housing
Choice Voucher 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 website. 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: 2018-PH-1005
                     Date: September 19, 2018

                     The Adams County Housing Authority, Gettysburg, PA, Did Not Administer
                     Its Housing Choice Voucher Program According to HUD Requirements




Highlights
What We Audited and Why
We audited the Adams County Housing Authority because (1) a news article reported that the
executive director received an excessive salary and practiced nepotism, (2) we received a
complaint alleging nepotism and potential misuse of Federal funds, and (3) we had never audited
the Authority. Our audit objective was to determine whether the Authority administered its
program according to applicable U.S. Department of Housing and Urban Development (HUD)
requirements.

What We Found
The Authority did not administer its Housing Choice Voucher Program according to HUD
requirements. The allegations regarding misuse of Federal funds and nepotism had merit. The
allegation regarding the executive director’s salary did not. The executive director’s HUD salary
did not exceed HUD limits. However, the Authority (1) violated HUD conflict-of-interest
requirements, (2) did not have a plan for allocating indirect payroll expenses, (3) did not
maintain documentation to show that it used its administrative fee for its intended purpose, (4)
did not always ensure that its program units met housing quality standards, and (5) improperly
inspected and performed rent reasonableness determinations on program units owned by an
entity that it substantially controlled. These conditions occurred because (1) the Authority was
unaware of HUD’s requirements, (2) it lacked controls to ensure compliance with all HUD
requirements, and (3) its inspector did not thoroughly inspect units. As a result, the (1) Authority
made ineligible payments totaling $279, (2) its use of administrative fees totaling $225,182 for
indirect payroll expenses and $47,376 for office rent were unsupported, (3) it made assistance
payments for units that did not meet housing quality standards, and (4) HUD could not rely on its
inspections and rent reasonableness determinations.

What We Recommend
We recommend that HUD require the Authority to (1) reimburse its program $279 from non-
Federal funds, (2) provide documentation to show that indirect payroll expenses totaling
$225,182 and office rent expenses totaling $47,376 were reasonable and necessary for the
administration of the program or repay its program from non-Federal funds, (3) develop and
implement controls to ensure that it properly uses administrative fees and has an independent
entity perform housing quality standards inspections and rent reasonableness determinations on
units owned by entities that it substantially controls, and (4) provide training to its inspector on
conducting housing quality standards inspections.
Table of Contents
Background and Objective......................................................................................3

Results of Audit ........................................................................................................5
         Finding: The Authority Did Not Administer Its Program According to HUD
         Requirements..................................................................................................................... 5

Scope and Methodology .........................................................................................10

Internal Controls ....................................................................................................12

Appendixes ..............................................................................................................14
         A. Schedule of Questioned Costs .................................................................................. 14

         B. Auditee Comments and OIG’s Evaluation ............................................................. 15




                                                                    2
Background and Objective
The Adams County Housing Authority was established in 1966. The Authority’s mission is to
provide safe, decent, and affordable housing opportunities to low-income families. It manages
nearly 600 housing choice vouchers that receive funding through the U.S. Department of
Housing and Urban Development (HUD) and two multifamily projects that receive rental
assistance through the U.S. Department of Agriculture’s Rural Housing Service program. It
owns an office building located at 40 East High Street, Gettysburg, PA, which it uses as its
office. In October 2004, the Authority refinanced its mortgage on the office building with the
U.S. Department of Agriculture. The Authority leases office space to two non-Federal, nonprofit
organizations: Pennsylvania Interfaith Community Program, Incorporated (PICPI) and Turning
Point Interfaith Mission, Incorporated (Turning Point). The nonprofit organizations provide
housing to low-income families in Adams County. Below is a photo of the Authority’s office
building.




The Authority is governed by a board of directors consisting of six members. The Authority and
the two nonprofit organizations have separate boards of directors and board members. The
Authority has no employees. All of the employees that work in the office building are PICPI
employees. PICPI lends its employees to the Authority to meet its operational needs. The
Authority pays PICPI for the salary and benefit costs of those employees. The Authority’s
executive director also serves as the executive director of PICPI and Turning Point. The
following diagram shows the relationship between the executive director and these organizations.




                                               3
                                     Executive director




                                        Pennsylvania                   Turning Point
       Adams County
                                    Interfaith Community             Interfaith Mission,
      Housing Authority
                                        Program, Inc.                        Inc.



Under the Housing Choice Voucher Program, HUD authorized the Authority to provide leased
housing assistance payments to nearly 600 eligible households in fiscal years 2016 and 2017.
HUD authorized the Authority the following financial assistance for housing choice vouchers for
fiscal years 2016 and 2017.


                             Year           Annual budget authority

                             2016                    $2,431,040
                             2017                     2,614,364

On August 30, 2017, a news article reported that the executive director received an excessive
salary and practiced nepotism. The article reported that the executive director collected three
salaries totaling $168,135 in 2016 and that the executive director’s son, sister and niece were
employed by the nonprofit organizations. On the same day, we received a complaint alleging
nepotism involving the executive director’s sister and son and questions concerning the
allocation of funds between the three organizations.

Our audit objective was to determine whether the Authority administered its program according
to HUD requirements.




                                                 4
Results of Audit

Finding: The Authority Did Not Administer Its Program According
to HUD Requirements
The Authority did not administer its Housing Choice Voucher Program according to HUD
requirements. The allegations regarding misuse of Federal funds and nepotism had merit. The
allegations regarding the executive director’s salary did not. The executive director’s HUD
salary did not exceed HUD limits. However, the Authority (1) violated HUD conflict-of-interest
requirements, (2) did not have a cost allocation plan for indirect payroll expenses, (3) did not
maintain documentation to show that it used its administrative fee for its intended purpose, (4)
did not always ensure that its program units met housing quality standards, (5) improperly
inspected units owned by an entity that it substantially controlled, and (6) improperly performed
rent reasonableness determinations on units owned by an entity that it substantially controlled.
These conditions occurred because (1) the Authority was unaware of HUD’s requirements, (2) it
lacked controls to ensure compliance with all HUD requirements, and (3) its inspector did not
thoroughly inspect units. As a result, (1) the Authority made ineligible payments totaling $279,
(2) its use of administrative fees totaling $225,182 for indirect payroll expenses was
unsupported, (3) its use of administrative fees totaling $47,376 for office rent was unsupported,
(4) it made housing assistance payments to owners of units that did not comply with housing
quality standards, and (5) HUD lacked assurance that its housing quality standards inspections
and rent reasonableness determinations for units owned by an entity that it substantially
controlled were reliable.

The Executive Director’s HUD Salary Did Not Exceed Established HUD Limits
The Consolidated Appropriations Act of 2016 allowed the chief executive officers of public
housing agencies to earn salaries, including bonuses, not to exceed the annual rate of basic pay
for a position at level IV of the Executive Schedule at any time during the public housing
agency’s fiscal year. The Consolidated Appropriations Act of 2017 repeated the provision for
fiscal year 2017. The Executive Schedule level IV pay rate was $160,300 for fiscal year 2016
and $161,900 for fiscal year 2017. The executive director earned a salary from the Authority and
the two nonprofit organizations totaling $166,430 in fiscal year 2016 and $172,238 in fiscal year
2017. However, the portion of the executive director’s salary paid by the Authority totaled
$53,473 for fiscal year 2016 and $55,467 for fiscal year 2017. The executive director’s HUD
salary did not exceed the established HUD limits for those years.

The Authority Violated HUD Conflict-of-Interest Requirements
The Authority’s consolidated annual contributions contract prohibited it from entering into a
contract in connection with the Housing Choice Voucher Program in which any employee of the
Authority who formulated policy or influenced decisions with respect to the program had a direct
or indirect interest. During the audit period, PICPI employed six persons who were related to the
executive director, which included the executive director’s son, sister, nephew-in-law, niece,
grandson, and granddaughter. PICPI hired these family members between 2009 and 2014. Of


                                                5
the six family members, three performed maintenance duties, two performed general custodial
duties, and one performed tenant intake duties. Payroll records showed that during the audit
period, only the grandson charged time to the program and earned $279. The grandson was a
seasonal, summer employee. The Authority had no documentation to show that it had requested
a waiver from HUD. None of the other five family members charged time to the Authority’s
Housing Choice Voucher Program. This condition occurred because the Authority lacked
controls to prevent and detect conflict-of-interest situations. Because the Authority violated its
consolidated annual contributions contract, the payment of $279 was ineligible.

In December 2017, the executive director’s son was permanently furloughed from his position
with PICPI because grant funds for his position had expired. In the same month, the executive
director’s employment was terminated by the Authority and the two nonprofit organizations
because the executive director violated PICPI’s personnel policy, which prohibited the executive
director from supervising family members.

The Authority Did Not Maintain a Cost Allocation Plan
Regulations at 2 CFR (Code of Federal Regulations) 200.416 required the Authority to develop a
cost allocation plan when certain services, such as accounting, were provided on a centralized
basis. PICPI provided 13 employees to the Authority to administer its Housing Choice Voucher
Program. Of the 13 employees, 11 performed centralized services, such as accounting,
management, inspection, and administrative services, for the Authority and the other nonprofit
organizations. The remaining two employees charged all of their time to administering the
program. During the audit period, the Authority charged indirect payroll expenses 1 totaling
$225,182 for the 11 employees who performed centralized services. The Authority did not
maintain a cost allocation plan to show how it allocated costs for the 11 employees. In October
2017, the Authority prepared and submitted a cost allocation plan to HUD. The purpose of the
plan was to summarize, in writing, the methods and procedures that it used to allocate costs to
various programs, grants, contracts, and agreements. The Authority stated that it had used the
method for allocating costs described in the plan for the past 20 years. The plan stated that costs
that benefited more than one program would be allocated to those programs based on the ratio of
each program’s salaries to the total of all program salaries. However, the timesheets reviewed
did not support this assertion. This condition occurred because the Authority was unaware that it
was required to maintain a cost allocation plan and it did not otherwise document the
methodology that it used to allocate costs that benefited more than one program. As a result, the
Authority’s use of $225,182 in administrative fees for indirect payroll expenses was
unsupported.

The Authority Could Not Support Its Use of Administrative Fees for Office Rent
During the audit period, the Authority transferred $1,974 monthly from its administrative fee
account to its management account 2 for office rent. The Authority transferred a total of $47,376


1
    Includes salary and benefit costs
2
    The Authority also deposited into this account the rent it collected from PICPI and Turning Point as well as rent
    it collected from renting spaces in its parking lot. From this account, the Authority made its monthly mortgage
    payments on its office building.



                                                           6
into this account during our 24-month audit period. PICPI moved most of the residual funds
from the Authority’s management account into a PICPI account monthly. However, the
Authority owned the office building and collected $8,799 3 in rent monthly from PICPI and
Turning Point. The Authority’s monthly mortgage payment was $4,749. Since the Authority
collected more rent than the amount of its monthly mortgage, we questioned the necessity of the
Authority’s payment for office rent. The Authority did not maintain documentation to show why
it made payments for office rent, how it calculated the $1,974 monthly amount, and how the
transfer of the funds to PICPI benefited the administration of the program. PICPI employees
stated that they did not know how the amount was calculated. This condition occurred because
the Authority lacked controls to ensure that it used administrative fees for their intended purpose
and maintained documentation to support their use. Regulations at 24 CFR 982.152(a)(3)
required the Authority to use its Housing Choice Voucher Program administrative fees only to
cover costs incurred to perform its administrative duties for the program. As a result, the
Authority’s use of administrative fees totaling $47,376 was unsupported.

Housing Units Did Not Always Meet HUD’s Housing Quality Standards
We performed observations on 14 of the 98 program units that passed an Authority-administered
housing quality standards inspection between August 27 and November 27, 2017. The 14 units
were selected to determine whether the Authority ensured that the units in its Housing Choice
Voucher Program met housing quality standards. As of April 2016, HUD regulations at 24 CFR
982.405(a) required the Authority to perform unit inspections before family move-in, at least
biennially during assisted occupancy, and at other times as needed to determine whether the unit
met housing quality standards. We conducted observations of the 14 units on December 6 and 7,
2017. Of the 14 housing units observed, 10 did not meet HUD’s housing quality standards
because they had 56 violations. However, none of the units were in material noncompliance
with HUD’s standards. Most of the violations were structural and materials violations that could
be easily corrected. None of the units was in extremely poor condition due to (1) deficiencies
that had existed for an extended period, (2) deficiencies noted in a prior inspection that had not
been corrected, or (3) deferred maintenance that consistently failed the unit. The violations
occurred mainly because the Authority’s housing inspector did not thoroughly inspect units and
did not identify obvious violations, such as a missing handrail. As a result, the Authority made
housing assistance payments to owners for units that did not comply with requirements.
Regulations at 24 CFR 982.401 required that all of the Authority’s program housing meet
HUD’s housing quality standards at the beginning of the assisted occupancy and throughout the
tenancy.

The Authority Improperly Inspected Units That It Substantially Controlled
The Authority did not comply with HUD requirements when it inspected program units owned
by an entity that it substantially controlled. For the same 14 units noted above, 2 units were
owned by PICPI, and 2 units were owned by Turning Point. Regulations at 24 CFR
982.352(b)(1)(iv)(A)(3) prohibited the Authority from inspecting units that it owned, including
units owned by an entity that it substantially controlled. The Authority was required to obtain
the services of an independent entity, approved by HUD, to perform these housing quality

3
    Of the $8,799 collected for rent, $6,302 was from PICPI, and $2,497 was from Turning Point.



                                                        7
standards inspections. In March 2014, the Authority entered into an agreement with a local
public housing agency to mutually provide inspection services on units owned by their affiliates,
which may have caused a potential conflict of interest. Although an agreement existed between
the two housing agencies, the Authority did not always use the local housing agency to inspect
units owned by PICPI or Turning Point. For three of the four units, the local housing agency
performed the initial inspections, which resulted in the units failing the inspection. However, the
Authority’s inspector performed the followup inspections, which resulted in the units passing the
inspection. For the remaining unit, the Authority’s inspector performed the initial inspection,
which resulted in the unit passing the inspection. This condition occurred because the Authority
lacked controls to ensure compliance with HUD requirements for inspecting program units
owned by an entity it substantially controlled. As a result, HUD could not rely on the
Authority’s housing quality standards inspections of the units owned by the two nonprofit
organizations that it substantially controlled.

The Authority Improperly Performed Rent Reasonableness Determinations on Units That
It Substantially Controlled
The Authority did not comply with HUD requirements when it performed rent reasonableness
determinations on units owned by an entity that it substantially controlled. Regulations at 24
CFR 982.352(b)(1)(iv)(A)(1) prohibited the Authority from performing rent reasonableness
determinations on units that it owned, including units owned by an entity that it substantially
controlled. The Authority was required to obtain the services of an independent entity, approved
by HUD, to perform these rent reasonableness determinations. However, the Authority
performed rent reasonableness determinations on program units that were owned by PICPI. This
condition occurred because the Authority lacked controls to ensure compliance with HUD
requirements for performing rent reasonableness determinations on units that it substantially
controlled. As result, HUD could not rely on the Authority’s determinations that the rents
charged for the PICPI units participating in the program were reasonable.

Conclusion
The Authority did not administer its program according to HUD requirements. It (1) violated
HUD conflict-of-interest requirements, (2) did not have a cost allocation plan for indirect payroll
expenses, (3) did not maintain documentation to show that it used its administrative fee for its
intended purpose, (4) did not always ensure that its program units met housing quality standards,
(5) improperly inspected units owned by an entity that it substantially controlled, and (6)
improperly performed rent reasonableness determinations on units owned by an entity that it
substantially controlled. As a result, (1) the Authority made ineligible payments totaling $279,
(2) its use of administrative fees totaling $225,182 for indirect payroll expenses was
unsupported, (3) its use of administrative fees totaling $47,376 for office rent was unsupported,
(4) it made housing assistance payments to owners of units that did not comply with housing
quality standards, and (5) HUD lacked assurance that its housing quality standards inspections
and rent reasonableness determinations for units owned by an entity that it substantially
controlled were reliable.




                                                 8
Recommendations
We recommend that the Director of HUD’s Pennsylvania State Office of Public Housing require
the Authority to

       1A.    Reimburse its program $279 from non-Federal funds for the ineligible payment it
              made due to the conflict-of-interest situation identified by the audit.

       1B.    Develop and implement controls to prevent and detect conflict-of-interest
              situations.

       1C.    Provide documentation to show that indirect payroll expenses totaling $225,182
              charged to the program were reasonable and necessary or repay its program from
              non-Federal funds for any amount that it cannot support.

       1D.    Develop and implement a cost allocation plan to use as a basis for charging
              indirect payroll expenses to the program.

       1E.    Provide documentation to show that administrative fees totaling $47,376 were
              used to perform administrative duties for the program or repay its program from
              non-Federal funds for any amount that it cannot support.

       1F.    Develop and implement controls to ensure that administrative fees are used to
              perform administrative duties for the program.

       1G.    Certify, along with the owners of the 10 units cited in the finding, that the
              applicable housing quality standards violations have been corrected.

       1H.    Provide training to its inspector on conducting housing quality standards
              inspections.

       1I.    Develop and implement controls to ensure that an independent entity performs
              housing quality standards inspections of units that it substantially controls.

       1J.    Submit a request for approval of an independent entity to perform rent
              reasonableness determinations for program units that it substantially controls.

       1K.    Develop and implement controls to ensure that the independent entity approved in
              recommendation 1J performs rent reasonableness determinations for program
              units that it substantially controls.




                                                 9
Scope and Methodology
We conducted the audit from October 2017 through September 2018 at the Authority’s office
located at 40 East High Street, Gettysburg, PA, and our office located in Philadelphia, PA. The
audit covered the period October 2015 through September 2017 but was expanded to include
units that passed an Authority-administered inspection in October and November 2017 because
we wanted to evaluate the current status of the Authority’s inspection program when we
conducted our observations in December 2017 and we did not want the time between the
Authority’s inspection and our observation to be more than 120 days.

To accomplish our objective, we reviewed

   •   Applicable laws, regulations, the Authority’s administrative plan and consolidated annual
       contributions contract with HUD, HUD’s program requirements at 24 CFR Part 982,
       requirements at 2 CFR Part 200, HUD’s Housing Choice Voucher Guidebook 7420.10G,
       and other guidance.

   •   The Authority’s inspection reports; computerized databases, including housing quality
       standards inspections, housing quality control inspections, housing assistance payments,
       and tenant data; tenant files; annual audited financial statements for fiscal years 2017,
       2016, and 2015; bank statements; interagency cooperation and management agreement;
       organizational chart; payroll reports and timesheets; draft cost allocation plan; and board
       meeting minutes.

We also interviewed PICPI staff, including the housing inspector; HUD staff; and program
households.

To achieve our audit objective, we relied in part on computer-processed tenant and housing
quality standards inspection data from the Authority’s computer system. Although we did not
perform a detailed assessment of the reliability of the data, we did perform a minimal level of
testing and found the data to be adequate for our purposes. The testing entailed comparing the
computer-processed data to the documents in the tenant files, including inspection reports.

We nonstatistically selected 14 of the Authority’s program units to inspect from a universe of 98
units that passed the Authority’s housing quality standards inspections from August 27 to
November 27, 2017. We selected the 14 units to determine whether the Authority’s program
units met housing quality standards. We observed the units on December 6 and 7, 2017. The
Authority’s inspector accompanied us on all 14 observations. Of the 14 units observed, 10
failed, and 4 passed our observation. Although 10 failed units had 56 violations, none of the
units was in material noncompliance with housing quality standards. Therefore, we did not
observe additional units and we did not project our audit results to the population.




                                                 10
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.




                                                11
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 program operations – Policies and procedures that
    management has implemented to reasonably ensure that a program meets its objectives.

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

•   Compliance with applicable laws and regulations – Policies and procedures that management
    has implemented to reasonably ensure that resource use is consistent with laws and
    regulations.
We assessed the relevant controls identified above.

A deficiency in internal control exists when the design or operation of a control does not allow
management or employees, in the normal course of performing their assigned functions, the
reasonable opportunity to prevent, detect, or correct (1) impairments to effectiveness or
efficiency of operations, (2) misstatements in financial or performance information, or (3)
violations of laws and regulations on a timely basis.

Significant Deficiencies
Based on our review, we believe that the following items are significant deficiencies:

•   The Authority lacked controls to
        o Detect and prevent conflict-of-interest situations.




                                                  12
       o Ensure that administrative fees are used for their intended purpose.
       o Ensure that an independent entity performs housing quality standards inspections and
         rent reasonableness determinations for program units that it substantially controls.

•   The Authority lacked a cost allocation plan to charge indirect payroll expenses.

•   The Authority did not thoroughly inspect program units.




                                                 13
Appendixes

Appendix A


                           Schedule of Questioned Costs
                 Recommendation
                                    Ineligible 1/  Unsupported 2/
                     number
                         1A                 $279
                         1C                                 $225,182
                         1E                                   47,376

                        Total               279              272,558



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.




                                              14
Appendix B
             Auditee Comments and OIG’s Evaluation



Ref to OIG    Auditee Comments
Evaluation




Comment 1




Comment 2




                               15
             Auditee Comments and OIG’s Evaluation




Ref to OIG    Auditee Comments
Evaluation




Comment 3




Comment 2




Comment 4




Comment 2




                               16
             Auditee Comments and OIG’s Evaluation




Ref to OIG    Auditee Comments
Evaluation


Comment 2




Comment 2




Comment 2




Comment 2




Comment 2




                               17
             Auditee Comments and OIG’s Evaluation




Ref to OIG    Auditee Comments
Evaluation




                               18
                         OIG Evaluation of Auditee Comments


Comment 1   The Authority concurred with the recommendation and stated that it will
            reimburse its Housing Choice Voucher Program $279 from non-Federal funds.
            As part of the audit resolution process, HUD will review the documentation
            provided by the Authority, determine whether it satisfies the recommendation,
            and provide its determination and the documentation to OIG for review and
            concurrence.
Comment 2   The Authority concurred with the recommendation. We acknowledge the
            Authority’s positive attitude toward the audit report and the recommendations.
            As part of the audit resolution process, HUD and OIG will agree on the necessary
            documentation to be provided by the Authority to show that its corrective actions
            satisfied the recommendations.
Comment 3   The Authority concurred with the recommendation and stated that it will provide
            documentation to HUD to demonstrate that $225,182 in indirect payroll expenses
            were reasonable and necessary to the Housing Choice Voucher Program. As part
            of the audit resolution process, HUD will review the documentation provided by
            the Authority, determine whether it satisfies the recommendation, and provide its
            determination and the documentation to OIG for review and concurrence.
Comment 4   The Authority concurred with the recommendation and stated that it will provide
            documentation to HUD to demonstrate that $47,375 in administrative fees were
            used to perform administrative duties necessary to the Housing Choice Voucher
            Program. (We noted that the Authority used the figure $47,375 rather than the
            $47,376 figure shown in the audit report. We attribute the one dollar difference
            between the figures to a typographical error by the Authority.) As part of the
            audit resolution process, HUD will review the documentation provided by the
            Authority, determine whether it satisfies the recommendation, and provide its
            determination and the documentation to OIG for review and concurrence.




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