Report 96-CH-201-1815 Assessment of Progress Chicago Housing Authority Chicago, Illinois Submitted To: Greg Russ, Director, Office of Troubled Agency Recovery Submitted By: Dale L. Chouteau District Inspector General for Audit, Midwest September 30, 1996 Executive Summary We completed a review of the Chicago Housing Author ity. The Secretary of HUD requested the review to assess the Authority's progress in eliminating its longstanding problems. In order to establish a foundation of the act ions needed to correct the Authority's problems, we used HUD's Blueprint for recovery issued shortly after HUD's takeover of the Authority; the Authority's Long- Term Plan; and its most recent Memorandum of Agreement with HUD. E ach of these documents laid out strategies and goals designed to increase the effectiveness of the Authority's operations so that it could be removed from HUD's troubled housing list. HUD issued its Blueprint for recovery on June 11, 1995. The Housing Authority issued it s Long-Term Plan on Febr uary 15, 1996, and prepared a draft Memorandum of Agreement dated June 21, 1996. Our assessment shows th at the Chicago Housing Authority is improving its operations on many different fronts. Many of the improvements made so far deal with the Housing Authority' s operational infrastructure where the impact is not readily noticeable. Nonetheless, th e improvements ar e necessary as a prelude to more visible changes. Although improvements are being made, the Chicago Housing Autho rity has much work to do before it will be operationally sound. Many of the Authority's actions have not been completed o r involve continuing activities. The Authority needs to periodically assess its action s to assure its initiatives correct the problems they were designed to address. The Housing Authority needs to make sure the actions it ha s initiated or planned are adjusted when necessary, and carried through to completion. I n addition, the Authority needs to be more diligent and aggressive in pursuing corrective actions in the areas of security, modernization, work orders, and preventive maintenance. With some exceptions, the Chicago Housing Auth ority is on The Authority Is Making target in implementing corrective actions relating to : Improvements on Many vacancy reduction and unit turnarounds, funding fo r Different Fronts maintenance and modernization activities, annua l inspections, housing management functions, admission s and evictions, rent collections, pro curement and contracting activities, accounting systems and controls, managemen t information system, asset management, risk management , personnel management, resi dent program delivery systems, economic development opportunities for residents , alternative funding sources, and the Section 8 program. The exceptions were caused by oversights o r misunderstandings of the objective of a strategy or goal . We made recommendations to address the exceptions. The actions which the Authority is pursuing in the areas liste d above, should, if completed as planned, significantl y improve the Authority's operations. Page i Office of Inspector General Executive Summary Although the Authority has initiated actions to improve its The Authority Needs To security, modernization and housing redevelopment, work Be More Diligent and order, and preventive maintenance operations, it needs t o Aggressive in Four Areas make significant adjustments in each of the areas before it can have an effective and efficient system that wil l adequately serve the residents. The Authority is pursuing security init iatives to improve the safety and living c onditions of its residents. The initiatives being undertaken are those that have worked at othe r housing authorities and/or were rec ommended by a security consultant. However, the Authority has not establishe d performance standards to periodically assess the results of the security initiatives it is undertaking. Consequently , although money is being spent on security, and securit y measures are being implemented, the Authority does no t have a means to readily determine wheth er the expenditures and actions are effective. The Authority has also initiated modernization an d redevelopment initiatives based on the HUD Blueprint, its Long-Term Plan, and the Memorandum of Agreement . However, the Authority has not completed a comprehensive physical needs assessment of each development and doe s not have a comprehensive plan for the overal l redevelopment of its properties. The Authority currentl y expects to have a plan completed after the year 2000. We believe this time frame is too far in the future. To ensur e the effective and effic ient use of limited modernization and redevelopment resources, a comprehensi ve plan needs to be developed as soon as possible. The Authority implemented a new work order system o n April 1, 1996. For the first time in many years, th e Authority has a reliable system to track its work orders . And, the news is not good. The new work order syste m shows that the number of backlogged work orders i s steadily increasing at a rate of over 10,000 a month. I t appears that the Authority may not have sufficient staff to address the work orders being received, muc h less eliminate the backlog. The Authority did not have a plan to address the work order problem. Instead, staff were hoping th e problem would go away as modernization an d redevelopment activities progressed. We are not a s Office of Inspector General Page ii Executive Summary optimistic. The Authority needs to conduct a capabilit y assessment of its maintenance staff to assess the quantity of work its staff can accomplish and determine whether it s maintenance staff level is sufficient to complete the dail y work orders and address the backlog. Using the results of the assessment, the Authority needs to develop a plan o f action to address the increasing number of work orders. Finally, the Authority has not implemented a comprehensive preventive maintenance program. Th e Memorandum of Agreement required this to be done b y June 30, 1996. Additionally, a preventive maintenanc e needs assessment for each development and a funding plan were not developed. The Authority's primary concern was on regular maintenance activities. However, an effectiv e preventive maintenanc e program needs to be established to detect and correct problems earlier, reduce the complexity of repairs, and ease the staff's workload. An effectiv e program should also free reso urces for regular maintenance activities. We gave the draft observations included in this report to the Authority's Deputy Executive Directors and the Chief o f Police during the review. We held an exit conference with the Authority's Executive Director and his Deputies o n September 11, 1996. The Authority provided writte n responses for each observation. The comments ar e included with each observation. The recommendations in this report will not be formall y controlled in HUD's Audits Management System . Appendix A contains a listing of all the recommendation s included in the report. We will follow up on th e recommendations at a l ater date after the Authority has had an opportunity to further improve its operations. Page iii Office of Inspector General Executive Summary THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page iv Table of Contents Executive Summary i Introduction 1 Chapters 1 Security 7 2 Modernization/Redevelopment of Housing 17 3 Work Order System 25 4 Preventive Maintenance 31 5 Vacancy Reduction/Unit Turnaround 35 6 Funding for Maintenance and Modernization 41 7 Annual Inspections 45 8 Housing Management Functions 51 9 Admissions and Evictions 57 10 Rent Collections 65 11 Procurement and Contracting 69 12 Accounting Systems and Controls 77 13 Management Information System 81 Page v Office of Inspector General Table of Contents 14 Asset Management 85 15 Risk Management 91 16 Personnel 95 17 Resident Program Delivery Systems 101 18 Economic Development Opportunities for Residents 109 19 Alternative Funding Sources 115 20 Section 8 119 Appendices A Recommendations 125 B Distribution 139 Office of Inspector General Page vi Introduction The Chicago Housing Authority was organized in 1937 under the housing laws of the State of Illinois. The Authority was established to develop, acquire, lease, operate and administer lo w rent housing programs. A turbulent internal administrative shakeup, that resulted in th e resignation of the Authority's Board of Commissioners, the Executive Director and other ke y management staff, left the Authority without a governing board or administrative leadership. As a result, on May 30, 1995, control of the Authority fell to HUD. While it has control of th e Authority, HUD has designated Edwin Eisendrath to serve as the Chairman of a five membe r Executive Advisory Committee. The Executive Advisory Committee serves the function of a Board of Directors. However, the Chairman has total a utonomy for all decisions. The other four Committee members serve only in an advisory role. Mr. Eisendrath is also HUD's Illinois State Office Secretary's Representative. The Authority's Executive Director is Joseph Shuldiner. The Chicago Housing Authority is the thir d largest public housing au thority in the Nation. TOTAL HOUSING UNITS: 55,487 It administers over 55,400 public housin g units located across the City of Chicago. The 51% 18% 28,480 units 9,822 units Authority has 42 family residential properties and 45 senior residential properties that ar e Federally funded or funded under the City - State Program. The City-State Program is a 3% 28% Section 8 Substantial Rehabilitation Program 1,489 units 15,696 units funded by the City and the State. Under th e Section 8 program, the Authority serves as landlord t o Scattered Sites Family Units provide housing to qualified applicants . Senior Units Approximately 1,489 of the Authority's units are scattered site houses located throughou t the city. All of the Authority's 87 properties are Authority, private, or resident managed. The Authority has over 15,000 units contracted under the Section 8 Certificate and Vouche r Programs. In Dece mber 1995, the Authority contracted with Quadel Consulting Corporation, a private firm, to operate and administer its Section 8 Program. The Authority has a tota l population of over 125,000 tenants. The population faces a multitude of social, economic and racial problems common to many of the Nation's inner city communities. Relative to other public housing authorities and public agencies, the Chicago Housing Authority is one of the mos t difficult and challenging agencies to operate because it has many severely distresse d developments and an extended scale of operations. Page 1 Office of Inspector General Introduction The Housing Authority received over $318 mil lion in HUD operating subsidies over the last two years. HUD also approved the Authority for the following additional funding: Sources of Funding 1993 1994 1995 Comprehensive Grant $135,432,295 $155,716,676 $145,090,576 HOPE IV 50,000,000 Modernization and 348,975 567,765 Lead Based Paint Vancancy Reduction 30,030,000 Program Drug Elimination 5,950,650 9,920,000 10,008,250 Grant Program 8,799,765 6,604,174 10,830,011 Since 1992, HUD has given the Authority over $701 million for the above programs. HUD and the Chicago Housing Authority's management have known about problems at th e Authority for many years. However, until HUD took control, a concerted effort to mak e significant improvements was not evident. Historically, the Chicago Housing Authority has been extremely resistant to take corrective acti ons sought by HUD. The Authority has been subjected to ineffective management and out-of-control bureaucratic systems, as well as politica l interference by City officials. The Authority has been classified by HUD as a troubled agency since HUD began using the troubled publ ic housing authority designation in 1979. As shown in the following chart, the Authority has consistently scored under 60 percent, the score required to be classified as a standard performer under the Public Housing Management Assessmen t Program: Office of Inspector General Page 2 Introduction PHMAP Scores 70% 60% 46.38% 48.69% 50% 45.65% 44.97% 40% 33.58% 30% 20% 10% 1991 1992 1993 1994 1995 Year Authority's Score Standard Performer To address the Authority's problems, the Deputy Ass istant Secretary for Distressed and Troubled Housing Recovery sent a Blueprint to the Secretary on June 11, 1995; the Authority developed a Long-Term Strategic Plan dated February 15, 1996; and HUD and the Authority drafted a Memorandum of Agreement dated June 21, 1996. The Blueprint identified HUD's goals as: (1) bringing meaningful, positive changes to th e Authority's residents, and (2) strengthening the Authority in order to provide a safe, decent and livable environment for its residents. As a result, the Authority has been operationall y restructured and its top managerial positions have been replaced. The Authority has a ne w Executive Director, Deputy Executive Director of Operations, Deputy Executive Director o f Finance and Administration, and Deputy Executive Director of Community Relations an d Involvement. In addition, the following areas were targeted for improvement: security ; maintenance; redevelopment; resident programs; the Authority's administration; asse t management; and building community commitment. With the change in the Authority's top manageme nt completed, the Authority developed a Long- Term Strategic Plan to effectively translate the HUD Blueprint into a functional mission-oriented improvement Plan. The Plan's mission is to ensure the provision of affordable housin g opportunities in viable communities for lower-income households. The Long-Term Plan's goals are to: (1) operate a well-managed and effective organization; (2) provide good housin g management; (3) change the face of public housing; (4) ensure safe liv ing conditions; (5) broaden educational, economic and recreational opportunities for the resi dents and their communities; and (5) build positive public awareness and engage overlapping governments. The Memorandum of Agreement established performance goals for the development of Page 3 Office of Inspector General Introduction management systems and programs for treating the severely distressed developments. It als o targeted the following areas for improvement: va cancies; rent collection; unit turnaround; annual inspection and repair to units and building systems; an d collection of tenant accounts receivable. The objective of our review was to assess the Chicag o Review Objective Housing Authority's progress in eliminating it s longstanding problems reported in past reports and reviews. Our review assessed the actions taken by the Authorit y Scope and Methodology between June 1, 1995, and May 30, 1996. The period was extended as necessary. We conducted on-site work fro m May through August 1996. We interviewed HU D personnel working wit h the Authority, consultants hired by the Authority, contractors, and the Authority's ow n personnel to determine the Authority's procedures an d assess actions taken or scheduled. We tested the accuracy and/or the effectiveness of: work order system procedures and status reports; vacancy unit/turnaround trackin g procedures and reports; inspection procedures; admissio n procedures; emergency purchase procedures; contractin g procedures; Section 8 quality control reviews; Section 8 recertification reports; workmen compensation reports ; information security policy; monitoring procedures fo r private management contracts; monitoring procedures fo r the deferred compensation program; and procedures t o track employee training. To asse ss the progress and quality of the Authority's actions to address its agreements wit h HUD and problems identified in past reports and reviews, we reviewed: • The June 11, 1995 HUD Blueprint • The Authority's February 15, 1996 Long-Term Strategic Plan • The March 6, 1996 and June 21, 1996 draft Memoranda of Agreement • HUD monitoring reports • Independent Public Accountants reports • Consultant studies • Public Housing Management Assessment Program records • HUD Office of Inspector General reports • The Authority's Office of Inspector General reports • CHAC's Section 8 reports Office of Inspector General Page 4 Introduction • The Authority's Memorandum of Agreement progress reports • The Authority's Fiscal Year 1996 Comprehensive Budget • The Authority's personnel records • The Authority's job descriptions, employee qualifications, training records and schedules, and training expenditures • The Authority's contrac ting and purchasing procedures, bid and contract award documents and requisition status reports • The Authority's inspection records and work orders • The Authority's policies and procedures for accounting systems, vacancy reduction, rent collection, tenant screening, evictions, security, management information system, work-orders, and Section 8 • The Authority's organization chart • The Authority's marketing and communication initiatives • The Authority's management information system software modules • The Authority's demolition plans, unit rehabilitation and project modernization plans and schedules • The Authority's vendor payment status reports and accounts receivable reports We provided a copy of this rep ort to the Executive Director of the Chicago Housing Authority. Page 5 Office of Inspector General Introduction THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 6 Chapter 1 Security On December 3 0, 1994, Carroll Buracker and Associates issued a report on its public safet y analysis of the Chicago Housing Authority's Police Department. The assessment showed tha t violent and drug related crimes concerned the Authority's residents the most. The followin g analysis of crime data shows that murder, aggravated sexual assault, and aggravated assault are higher on the Authority's property than in Chicago or other major cities. HIGH FEAR CRIME RATES A Comparison of Crime Rates in Major Cities, Chicago and Chicago Housing Authority - 1992 10000 1000 3129 100 239 1452 72 133 988 10 33 30 54 1 Murder Sexual Aggravated Assault Assault Major Cities Chicago Chicago Housing Authority In 1992, homicides, criminal sexual assau lts and aggravated assaults occurred on the Authority's properties at rates two to three times that on non-Authority pr operties. Although the situation has improved, in 1995 the Authority's residents were still twice as likely to face one of these crimes than other people in Chicago. HUD's Blueprint, the Authority's Memorandum of Agreement with HU D and its Long-Term Plan contain goals to maximize service and increase safety on the Authority's properties and t o significantly reduce annual security costs. The Memorandum of Agre ement and Long-Term Plan incorporate the recommendations in the Buracker Report. Measuring security initiatives. The Chicago Housin g Observations Authority's Police Department did not have an adequat e system to evaluate the success of the security initiatives that have and will be implemented. In response to a recommendation in the Buracker report, the Authorit y established a Research and Development Unit to compil e and analyze crime statistics for the Authority' s developments. The Unit also monitors the Authority' s Page 7 Office of Inspector General Chapter 1 progress in meeting HUD's Blueprint, its Memorandum of Agreement, and Long-Term Plan goals and strategies, and the Buracker Report recommendations. Although th e Authority was monitoring the implementat ion of its security initiatives, it did not identify the performance standard s expected to result from each initiative. Th erefore, there was no reliable or reasonable way to assess the effectiveness of each individual initiative regarding the reduction an d prevention of crime. Before implementing a security initiative, the Authorit y needs to identify its objective and establish realistic criteria that can be used to measure the achievement of th e objective. The Authority also needs to est ablish target dates to evaluate the initiative so that it can assess progress an d pursue those initiatives that have the greatest impact o n reducing crime and maintaining a safe living environment. Realistic measurement criteria would also provide th e Authority's management with a sound basis on which t o make decisions to reduce security costs. We recommend HUD assures the Authority develops procedures and controls to establish and evaluate performance measures for each security initiative undertaken. Performance measures should be established for each initiative outlined in the Blueprint, Memorandum of Agreement, Long-Term Plan, and the Buracker Report. Although the Authority does not currently have a soun d basis to measure the effectiveness of its initiatives, th e strategies resulting from the Blueprint, Memorandum o f Agreement and Long-Term plan stem from actions tha t have worked at other locations and/or were recommended by an expert security consultant. As a result, most of th e initiatives should help to improve security, although th e extent of the improvement and which initiatives are mos t effective cannot be determined. HUD's Blueprint, th e Memorandum of Agreement, and the Long-Term Pla n initiatives can be divided into the following thirteen areas: tenant patrols; community policing; contract security ; employee hires; resident hires; networking with other la w enforcement agencies; crime statistics; tactical teams ; Office of Inspector General Page 8 Chapter 1 specialized units; internal communication; the reduction of security costs; house rules; and site-based security. We reviewed these 13 areas to assess if the Authority was initiating actions to improve security in accordance wit h HUD's Blueprint, its Memorandum of Agreement an d Long-Term plan. The Authority had initiated actions an d was on target to meet its goal s in 10 of the 13 areas. In two of the areas the Authority needs to initiate actions if it is to meet its target dates and in one area HUD needs to tak e action to provide the Authority a firm goal. Security initiatives. Following are some examples of the strategies the Authority has initiated and is on schedule to meet its target dates: Tenant patrols. The mission of the Tenant Patrol is t o enhance the quality of life in the Chicago Housin g Authority community by assisting in crime reduction an d building maintenance efforts. The Chicago Housin g Authority Tenant Patrol is a group of concerned residents. Tenant Patrol personnel are trained and are governed by a Code of Conduct. They patrol, observe and report crime , and/or physical conditions that are hazardous to the safety and well being of the community. The first Tenant Patrol was established in 1989 at a building in the Cabrini Green Development located at 1230 Nort h Burling. As of August 26, 1996, the Authority ha s established 32 Tenant Patrols at 14 of the Authority's 4 2 family developments and 36 Tenant Patrols at 32 of its 45 senior developments. However, not all buildings in thes e developments had tenan t patrols. For example, the Cabrini Green Development has 27 buildings; however, there ar e only six buildings with tenant patrols. There are 54 9 residents participating in Tenant Patrols. During the nex t quarter, the Authority plans to initiate patrols at Altgel d Gardens, Leclaire Courts, Madden Park Homes, Odge n Courts, and Robert Taylor A-1 and A-2. Community policing. The Chicago Housing Authorit y Police Department is currently in the process of movin g from a traditional vehicular patrol/response oriented police force to a community oriented policing force. Th e Page 9 Office of Inspector General Chapter 1 Authority has decided to reduce its heavy reliance on th e deployment of contract security guards in the lobbies o f buildings. Contract guard security will be replaced by communit y policing teams in the Authority's developments. Th e objective of the community oriented policing strategy is to assign a team of police officers and Authority securit y guards who are trained in community policing concepts to a development. The police and guards will interact wit h residents to gain their confidence and assistance i n identifying perpetrators of crime. Security personnel wil l no longer limit themselves to controlling the lobbies of the buildings. The Community Policing Teams work in conjunction with the development's Tenant Patrol. The Authority ha s implemented community policing at eight famil y developments. The first Community Policing Team wa s established in 1992 at the Ida B. Wells Development. Between January 1996 and May 1996, the Authorit y initiated the community oriented policing strategy a t Altgeld Gardens, ABLA Homes, Cabrini Green, Dearborn Homes, Henry Horner Homes, Ickes, and Robert Taylo r Homes. In September 1996, the Authority plans to initiate community policing at the Hilliard Development. The Community Oriented Policing Strategy in the Long - Term Plan includes initiatives for the construction of "mini- stations". The "mini-stations" have a space for th e temporary detention of offenders and a safe for evidenc e recovery. A "mini-station" w as opened in the Ida B. Wells Development in 1993. In January 1996, "mini-stations " were opened in the Cabrini Green and ABLA Home s Developments. The next development scheduled for th e construction of a "mini-station" is Rockwell Gardens. Contract security. To reduce security costs the Authorit y has started to phase-out contract security guard servic e throughout the developments. Betw een June 1995 and July 1996, the Authority has reduced the contract staff b y approximately 50 percent from 900 guards t o approximately 450 guards. Plans are being developed for Office of Inspector General Page 10 Chapter 1 the removal of the remaining contract service guards at all family developme nts. The Authority's Chief of Police said the reduction of the contract security force will b e completed by August 1997. Site-based security plans. The Authority has not initiated the Memorandum of Agreement and Long-Term Pla n strategies for the development of site-based security plans. The development of site-based security plans was originally a recommendation in the Buracker report. Th e Memorandum of Agreement's target completion date for the development of all site-based security plans an d performance measures is December 31, 1997. However , the Authority established a target completion date, in it s Long-Term Plan, of December 31, 1996 for th e development of site-based security plans at the Cabrin i Green, Ida B. Wells, Altgeld Gardens, and ABLA Home s developments. The sec urity plans entail a detailed analysis of: crime patterns for each development; what patrols are needed to combat the crime specific to the development ; equipment needs; and physical improvements needed t o enhance security measures. Therefore , unless the Authority immediately begins to develop th e plans, it will not meet its December 31, 1996 target. The Authority's Police Department has an Authority-wid e deployment plan based upon crime patterns and ha s initiated the Community Oriented Policing Strategy a t certain family develop ments. However, it is imperative for the Authority to develop a formalized site-based securit y plan for each of its developments in order to prioritiz e initiatives and provide the most effective security at th e lowest cost. We recommend HUD assures the Authority immediately starts to develop site-based security plans for the Cabrini Green, Ida B. Wells, Altgeld Gardens, and ABLA Homes developments. We also recommend HUD monitors the Authority ot ensure it develops all site-based security plans by December 31, 1997. Page 11 Office of Inspector General Chapter 1 House rules. The Authority has not initiated th e Memorandum of Agreement and Long-Term Pla n strategies to develop house rules. The Memorandum of Agreement and Long-Term Plan's target completion dates for th e development of house rules is December 31, 1996. House rules establish a code of conduct for residents an d guests to follow. The rules are an extension of the lease , and provide tenant patrols and Authority police a means to regulate tenants' behavio r before it could get out of control. Violators are subject to fines and in extreme cases can b e evicted. As of August 8, 1996, when we initially inquired about this goal, the responsible personnel for development and implementation were not aware of what the initiativ e entailed or when action would be taken. We recommend HUD assures the Authority develops house rules by December 31, 1996 and immediately begins to enforce the rules. Security costs. The Chicago Housing Authority's security costs increased from $6.8 million in 1988 to an actua l expenditure of over $70 million in 1995 . The 1995 security expenditures supported: approximately 450 contrac t security guards, 300 Authority security guards and 46 0 sworn Authority police officers; security and police officer training; and physical and technical security equipment . The following graph details the Authority's securit y e x b 1 a 1 $80,000 $73,948 $70,000 $65,482 $58,314 $60,000 $50,000 $41,118 $40,000 $29,100 $30,000 $22,268 $20,000 $10,476 $10,000 $6,800 $0 1988 1989 1990 1991 1992 1993 1994 1995 Office of Inspector General Page 12 Chapter 1 Because escalating security costs have largely been pai d from Comprehensive Grant funds, the Authority has ha d less funds to properly maintain and improve it s developments. As a result, HUD has requir ed security costs to be reduced; however, since the Memorandum o f Agreement that contains the reduction goal has not bee n signed the Authority does not know the amount of funds it must reduce. The latest draft Memorandum of Agreement dated June 21, 1996 states that the Chicago Housin g Authority will cut its security costs by 10 percent per year for 1997 and 1998. This would amount to approximately a $12 million total reduction for the two years. On August 2, 1996, the Acting Assistant Secretary for the Office o f Public and Indian Housing mandated that the Illinois State Office assure that the cost savings tota l $25 million over the two year period. Since the final Memorandum of Agreement could chang e the $25 million amount, the Auth ority does not have a clear goal to work towards. The Authority initially determine d its security costs could be decreased through reductions in contract guards and administration, Authority securit y guards and administration, and Authority polic e administration. T hese tentative reductions for the two year period totalled appro ximately $12.1 million, the goal in the June 21, 1996 draft Memorandum. However, in order for the Authority to effectively address overall security cos t reductions it needs to have a firm target. Page 13 Office of Inspector General Chapter 1 We recommend HUD completes the Memorandum of Agreement and provides the Authority with a firm funding target so the Authority can make decisions regarding the most effective way to cut costs while maintaining the highest level of security possible. We recommend HUD allows the Authority sufficient time to evaluate its security initiatives in accordance with our first recommendation before requiring adherence to a cost reduction plan. The Chicago Housi ng Authority's Chief of Police provided Management's Comments the following comments: Measuring Security Initiatives Agree. The Chica go Housing Authority Police Department has established a methodology to evaluate the effectiveness of each security initiative. However, two of the thirtee n initiatives (Tenant Patrol and House Rules) ar e resident/management driven rather than security driven . The Police Department is presently assisting residen t organizations and management in both areas. Tenant Patrols We agree. Community Policing The Chicago Housing Authority Police Department i s revising its Community Oriented Policing strategy base d upon expected budget cuts. Authority security guards will be deployed as a support component in the revised strategy. Contract Security Contracted guards have been reduced throughout th e Authority. Resident based security employment contracts will delay the total removal of contract guards from family high rise housing until January 1, 1998 . Gradual reductions will occur throughout Fiscal Year 1997. Site-Based Security Plans Office of Inspector General Page 14 Chapter 1 We agree. Site-based security plans for ABLA, Cabrin i Green, Wells and Altgeld are presently in draft form , pending the firm "target" from HUD which may requir e changes in the plans. Purchasing and Contr acts is preparing a Request for Proposal for a technical assistance provide r (security consultant) to complete physical assessments for site-based security plans. House Rules We agree. The resident and various managemen t organizations should develop House Rules. The Polic e Department is currently assisting in establishing an d facilitating committee s throughout the Authority to address this issue. We believe the Authority's Chief of Police did not full y Evaluation of Comments understand the intention of our first recommendation t o measure security initiatives. At the time we completed our review (August 16, 1996), the Authority did not have a methodology to evaluate the effectiveness of each of it s many security initiatives. We div ided the initiatives into 13 general areas; however, many more than 13 initiatives have been undertaken. We believe the Authority needs t o develop procedures and controls to establish and evaluat e performance measures for each specific security initiativ e undertaken. Page 15 Office of Inspector General Chapter 1 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 16 Chapter 2 Modernization/Redevelopment of Housing Previous consultant and independent public accountant reports found problems pertaining to the modernization/redevelopment of the Chicago Housing Authority's housing. The Authority did not have a comprehensive and coordinated strategy to address its problems. HUD's Blueprint dated June 11, 1995, contained a goal that required the Authority to demolish obsolete high-rise buildings and replace them with less dense, smaller buildings at the Henr y Horner, Cabrini Green, Lakefront and Washington Park developments. In addition, th e Authority's Long-Term Plan, dated February 15, 1996, contained a goal to create smaller scale, less dense housing that is indistinguishable from the broader community. Finally, the draf t Memorandum of Agreement dated July 21, 1996 between the Authority and HUD co ntained three goals to: determine the condition of the housing stock; develop plans that incorporat e development stra tegies into neighborhood revitalization plans; and develop a marketing plan to support full occupancy in viable buildings and developments. Comprehensive Plan. Although the Authority plans t o Observations redevelop its Cabrini Green, Henry Horner, Lakefront , Washington Park and Clarence Darrow developments; i t does not have a comprehensive plan for the overal l redevelopment of the five developments or any of its other developments. Instead, it has developed plans to addres s only certain buildings and systems at each site, not th e entire sites. Upon completion of its Long-Term Plan the Authority will have developed a comprehensive physical need s assessment/development activity plan. However, this plan will not be available until after the ye ar 2000. Waiting until 2000 to develop a comprehensive development a ctivity plan is too long since the plan should be the basis for a systematic method to efficiently use resources for th e maximum benefit of residents. In accordance with the Memorandum of Agreement, th e Authority is planning to complete a viability study with a 20-year cash needs assessm ent and a marketing study. The 20-year cash needs assessment is scheduled to be completed September 30, 1996 and the mar keting study December 31, 1996. After the Authority complete s the viability study and marketing plan, it needs to use the results to immediatel y develop a comprehensive plan that will ensure that th e stable developments are maintained in good r epair while the Page 17 Office of Inspector General Chapter 2 Authority addresses deteriorated conditions at the othe r developments. A comprehensive plan should identify what developments and buildings are viable and what is needed to maintai n their long-term viability. In addition, it should provide a consistent approach to ensure that money is spent t o achieve the greatest return to the Authority. A consultan t report dated October 28, 1994 stated that a comprehensive and coordinated strategy for addressing the needs of th e public housing program is absolutely necessary if th e problems faced by the Authority and the residents it serves are to be addressed. The study stated that due to the extremely high cost o f comprehensive modernization, the Authority chose a piecemeal approach, attacking the most acute problem s first. The Authority's decision to use disproportionat e amounts of modernization money on one or more severely distressed developments forced a lower priority for routine modernization at other develo pments. The end result being the deferral of repairs that, over the long run, will result in higher capital improvements and operating costs. To ensure that the developments achieve long-ter m viability, the Authority also needs to ensure that th e comprehensive plan incorporates the results of th e marketing study scheduled to be completed as part of th e Memorandum of Agreement. For example, the Authorit y is currently rehabilitating three buildings at its Henr y Horner annex. The rehabilitation plans require that th e parking lots be repaired. Howe ver, the plans do not require that there be a parking s pace for each unit. The Authority's long-term objective is to market its units to higher income individuals to obtain a mixed income population. Limited parking could be an impediment to this objective. We recommend that HUD requires the Authority ot develop a comprehensive modernization/redevelopment plan for all of its developments once the viability assessment and marketing plan have been completed. The plan should consider and incorporate the results of the marketing study and viability assessment. Specifically, the plan should identify developments by Office of Inspector General Page 18 Chapter 2 categories such as stable, high-needs and non-viable developments. In addition, the plan should identify all planned demolition and rehabilitation by building with the costs necessary to make the repairs. Blueprint. HUD's Blueprint for the Authority established a redevelopment goal to demolish obsolete high-ris e buildings and replace them with less dense, smalle r buildings. Specifically, the goal required the Authority to: demolish five buildings, relocate day care operations an d begin construction of replacement housing at H enry Horner; demolish three buildings, complete relocation of residents and begin construction of replacement housing at Cabrin i Green; demolish five buildings and begin construction o f replacement housing at Lakefront; and work with Cit y officials to identify land for scattered s ite housing and begin to construct replacement housing at Washington Park. Although, the Authority has not completed its Blueprin t goal, it has made significant progress. At Henry Horner , the Authority demolished three buildings and HUD ha s approved the demolition of two more buildings. Th e additional two buildings will be demolished upon cour t approval. In addition, three build ings consisting of 98 units are being rehabilitated and the Authority has started th e construction of the planned 466 on-site replacemen t housing units. The first 20 units will be completed b y December 1, 1996 and all 466 units are scheduled to b e completed by the fall of 1998. At Cabrini Green, two buil dings have been demolished and HUD has approved the demolition of a third in Augus t 1996. The Authority has negotiated with the City t o redevelop the entire Cabrini Green neighborhood. Th e initial plans include the demolition of eight buildings with private developer s constructing 1,400 new residential units and the Authority constructing 600 to 650 public housin g units. Redevelopment of the Lakefront and Washington Par k developments was delayed because of a lawsuit filed b y neighborhood residents. The Lakefront and Washingto n Park developments are in cl ose proximity to each other and Page 19 Office of Inspector General Chapter 2 neighborhood residents su ed to prevent the development of 241 family public housing units. On June 3, 1996, the Authority obtained court permissio n to build the replacement housing for Lakefront an d Washington Park. The Habitat Company, the corporation retained to manage an d develop scattered site housing, was appointed to obtain properties for the construction of th e scattered site replacement housing. The court decisio n stated that no more than 150 of the 241 replacement unit s could be built on the Lakefront and Washington Par k properties. The Authority has demolished all t he units (187) planned to be razed at Washingto n Park and has entered into a revised agreement with former Lakefront tenants to demolish four high-rise buildings at Lakefront. However, the Authorit y must now develop specifications and a Request for Proposal before the demolition of the buildings can occur. Based on the agreement, the Authority can not demolish additiona l Lakefront buildings until it enters into binding fundin g agreements with HUD to build replacement housing. The replacement housing has to be first offered to the displaced residents of Lakefront. Long-Term Plan. The Long-Term Plan contains fiv e strategies related to redevelopment. Although the Blueprint contains goals for five develop ments, those for Washington Park were not incorporated in the Long-Term Plan. Th e Deputy Executive Director of Operations said he did no t know why Washington Park was omitted from the Long - Term Plan. However, as previously stated, there is n o comprehensive plan to address all developments. Th e Long-Term Plan is not satisfactory in its elf, since the timing of the comprehensive plan is too far in the future. Th e Long-Term Plan strategies are to: establish and implement plans for redevelopment at Cabrini Green, Henry Horner , Lakefront and Clarence Darrow; and develop plans tha t blend with neighborhood strategies to replace obsolet e high-rises and other non-viable buildings at othe r developments. The Long-Term Plan strategies hav e targeted milestones with completion dates after December 31, 1996. Several of the milestones have schedule d completion dates through the year 2000. Office of Inspector General Page 20 Chapter 2 We recommend that HUD assures the Authority develops controls to ensure all plans, including the comprehensive plan to be developed, are consistent. The Authority has i nitiated actions on the target milestones scheduled to begin in 1996. Specifically, it has: proceeded with demolition and relocation of tenants at Cabrini Green and announced plans t o, with the assistance of the City and private developers, develop an entire neighborhood ; performed demolition and i s in the process of rehabilitation and new construction at Henry Horner; obtained tenan t approval for demolition and cour t approval for construction of new units at Lakefront; and started demolition a t Clarence Darrow. However, the Authority has no t developed overall redevelopment plans for the Cabrin i Green, Henry Horner, Lakefront and Clarence Darro w developments. The strategy to develop plans t hat blend with neighborhood strategies to replace obsolete high-rises and other non - viable buildings at other developments is largely futur e oriented. Six of the seven milestones are not scheduled to be completed until after 2000. The seventh milestone, t o conduct comprehensive community revitalization plans, is on going and should be completed by the target date o f March 31, 1997. Memorandum of Agreement. The Memorandum o f Agreement has three goals that have future completio n dates as follows: March 31, 1997 to determ ine the condition of the housing stock; March 31, 1997 to develop plans that incorporate development strategies into neighborhoo d revitalization plans; and December 31, 1996 to develop a marketing plan to support full occupancy in viabl e buildings and developments. The Authority has sufficient time to meet its March 31, 1997 target dates for the first two goals, however; the Authority will not meet its goal t o develop a marketing plan to support full occupancy i n viable buildings and developments by the December 31 , 1996 target date. The goal to develop a marketing plan consists of thre e strategies: (1) complete a marketing study; (2) incorporate Page 21 Office of Inspector General Chapter 2 the study into a capital needs ass essment; and (3) determine which viable developments are marketable, and to whom. Since the marketing plan is to support full occupancy i n viable buildings, it is necessary for the Authority t o determine which units are viable before a marketing plan is developed. As part of the Memorandum of Agreement goal to determine the condition of the housing stock, th e Authority has a strategy to perform a viability assessmen t with a 20-year cash needs forecast. The strategy has a September 30, 1996 target date. As of August 16, 1 996, the Authority was in the process of contracting for a viability assessment an d needs assessment. The Authority intends to use a consultant already unde r contract to complete the study and assessment. Th e Authority requested that the consultant respond to a scope of services by August 16, 1996. Until the response is received and evaluated it is not known how long the assessment will take. The Authority estimates the study will take six weeks. Therefore, the Authority will not have a completed viability assessment by the September 30, 1996 target date and will not be able to develop a marketing plan by December 31, 1996. The Deput y Executive Director of Operations said the viabilit y assessment should be completed no later than December 31, 1996 and the goal to develop a marketing plan will b e completed by March 31, 1997. The Director said thes e short suspense dates are obtainable since the need s assessment will be prepared by the c ontractor who prepared the previous assessment and is familiar with th e requirements. We recommend that HUD continues to closelywatch the Authority's progress in implementing its modernization and redevelopment efforts. HUD should provide technical assistance to ensure the modernization and redevelopment goals are fully implemented. We recommend that HUD assures the Authority meets the Deputy Executive Director's revised target dates to perform a viability assessment with a 20-year cash Office of Inspector General Page 22 Chapter 2 needs forecast by December 31, 1996 and develop a marketing plan by March 31, 1997. Management's Comments The Authority's Deputy Executive Director of Operation s said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Page 23 Office of Inspector General Chapter 2 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 24 Chapter 3 Work Order System Previous consultant, HUD and Chicago Housing Authority Office of Inspector General reports found problems pertaining to the Chicago Housing Authority's maintenance work orde r procedures and performance standards. HUD's Blueprint dated June 11, 1995, required the Authority to standardize and centralize it s work order system. In addition, the Authority's draft Memorandum of Agreement dated June 21, 1996 contains three goals to: develop and implement a work order control and scheduling system that will automate preventive and routine maintenance, expedite abatement of emergency work orders and enhance the Authority's unit turnaround capacity; abate all emergency work order s within 24 hours; and complete all non-emergency work orders in an average of 30 to 35 days. Memorandum of Agreement and Blueprint. The Observations Memorandum of Agreement contains twelve, short-ter m strategies to meet its goals. Of the twelve strategies, th e Authority has completed the following six: • Develop policies and procedures for the work orde r system. • Train staff on entry and close-out procedures fo r emergency and non-emergency work orders. • Determine whether work orders will be taken at a central location or at all developments. • Train housing and maintenance staff on the compute r system. • Train, monitor and evaluate site manager performance. • Assess methods of receiving work orders and th e accuracy of work order close-out. In addition, the Authority has progressed toward th e completion of three other strategies that have future target dates: • Implement the work order system module at a site - based level and in tegrate with central office work order functions. • Train staff on work methods and procedures. • Monitor and evaluate the weekly performance an d productivity of maintenance staff. Although the Authority has completed six str ategies and has three strategies in progress, additional work is needed t o Page 25 Office of Inspector General Chapter 3 achieve its long-term goals. For exa mple, the Authority did not fully implement the remaining three Memorandum o f Agreement strategies that had completion dates of June 30, 1996. The three strategies were: • Review and revise emergency work order definitions , policies and procedures. • Review, revise and distribute work order definitions , policies and procedures. • Train maintenance superintendents and supervisors t o schedule and prioritize work orders. Written policies and procedures. The Authorit y developed policies and procedures for its work orde r system. However, the policies and procedures fo r emergency work orders were not sufficient to operate a n effective work orde r system and were not distributed to the appropriate personnel. The policies and procedures did not contain instructions to ensure that emergency conditions cited during Housin g Quality Standards inspections were identifie d and addressed within 24 hours. It is important to have procedures tha t address all emergency conditions so that emergency work orders can be abated within a 24-hour time frame. We contacted thr ee maintenance superintendents to review their copies of the work order procedures. Each of the three superintendents said he did not have any written procedures regarding the new work order s ystem. Because the policies and procedures had not been distributed, some employees did not follow the work order procedures. To close a work order out of the system, the procedures require that th e signatures of the resident and maintenance superintendent appear on each work order. Out of a sample of 10 close d work orders, one was missing the super visor's signature and another was missing the tenant's signat ure or an explanation of why the signature was not obtained. Although it is no t always feasible to obtain the resident's signature, th e procedures stipulate that an explanation is required in lieu of the signature. The Authority was in the process of revising it s maintenance manual to include policies and procedures for Office of Inspector General Page 26 Chapter 3 the new work order system. The Authority plans to hav e the policies and procedures completed by August 31, 1996. Written policies and procedures, properly distributed t o applicable personnel, are especially important with a ne w system to ensure consistency and adequate control. We recommend HUD assures the Authority reviews its work order policies and procedures, develops procedures to operate the system effectively, and includes the new procedures in itsmaintenance manual. We recommend HUD assures the Authority promptly distributes the revised maintenance manual to all applicable personnel. Maintenance superintendent and supervisor training. In January 1996, the Authority established a class in work order management. However, only three of over 5 0 maintenance superintendents and s upervisors have attended the training. The rest of the superintendents an d supervisors are scheduled to be trained between July an d December 1996. In consideration of the many c hanges with the new system, it is important that all superintendents and supervisors be expeditiously trained on the new procedures. Training should enhance customer service and consistency in work order procedures. We recommend HUD assures the Authority trains all its maintenance superintendents and supervisors on work order procedures by December 31, 1996. New computerized work order system. The Authorit y began using a new computerized work order system o n April 1, 1996. Prior to the implementation of the ne w system, the Authority did not have a reliable way to trac k outstanding work orders. The new system when full y implemented will provide greater account ability and control over work orders. However, the following problem needs to be corrected. The number of outstanding work orders has steadil y increased since the new system was implemented on April 1, 1996. At the end of April there were 15,075 backlogged Page 27 Office of Inspector General Chapter 3 work orders, 33,607 at the end of May, and 49,441 at th e end of June. Work orders are created by technicians at the Custome r Service Center. Five times daily, technicians cue the work orders to print at the on-site printer of the appropriat e development. However, the work orders were not always received at the developments. Work orders did not always print, printed at the wrong developments, and on-sit e printers jammed because they could not handle larg e numbers of work orders. When the printers jammed, work orders got lost in the system and did not reprint. Th e erroneous distribution of work orders resulted in delays in getting them to the correct locations. The printer problems contributed to the untimely completion of work orders and an increased backlog. The following table summarizes the open work orders by priority code, and shows the number of work orders and average days outstanding. AGED OUTSTANDING WORK ORDERS FOR ALL DEVELOPMENTS AT 6-30-96 Priority Number of Average Code Work Orders Days (rounded) Emergency 1,113 49 Routine 27,455 53 Annual Inspection 14,276 55 Urgent 3,446 44 Code Violation 2,764 60 Missing 228 55 Extraordinary 87 24 Maintenance Preventive 72 39 TOTAL 49,441 Office of Inspector General Page 28 Chapter 3 Management at the developments did not immediatel y identify the problem because they did not receive weekl y reports that gave work order status. The Authority became aware of the printer problems at the developments in May 1996 and believed the problem was a systems problem. The Authority increased the speed o f the central data bank spooler and purchased a nd installed 16 new printers with larger capacity. However, these changes did not correct the backlo g problem. The backlog increased 15,834 in June an d another 10,221 during July. The large number o f outstanding work orders should be an immediate concern to the Authority because it directly correlates to the Publi c Housing Management Assessment Program and poo r customer service. If the backlog is not reduced, the average number of days to complete emergency and routine wor k orders will increase and the Authority will receive a failing grade for completion of emergency and routine wor k orders. Since the number of backlogged work orders has steadil y increased, even during the period when adjustments wer e made, it appears the probl em is not totally systems oriented and the Authority may not have sufficient staff to addres s the work orders being received, much less t he backlog. The Authority, however, did not have a c apability assessment of its maintenance staff. Performance standards. As of April 1, 1996, th e Authority established new performance standards for it s maintenance personnel. However, due to the recen t implementation of the work order system, the performance standards were not being used. The Authority plans t o implement the new standards in its January 1, 199 7 performance evaluations. Without an effective method of assessing sta ff performance, the Authority cannot determine the effectiveness an d efficiency of its maintenance employees. Furthermore , until the Authority implements the performance standard s and can assess the quantity of work its staff shoul d accomplish, it cannot determine whether the maintenanc e Page 29 Office of Inspector General Chapter 3 staff level is sufficient to complete the daily work order s and address the backlog. The Authority's Deputy Executive Director of Operation s said he believes the bac klog problem will be resolved upon completion of other initiatives the Authority has undertaken such as, the demolitions and rehabilitations under it s modernization progr ams. As more buildings are renovated and demolished, the number of new work orders shoul d decrease, since there will be fewer units and the units tha t do exist will be in better condition. The reduction of ne w work orders shou ld provide more time for the maintenance staff to address the work order backlog. However, th e Authority has no plan of action i f this is not the case. Since the Authority's main objective should be to provide decent, safe, and sanitary housing for low and moderate incom e persons, the Authority needs to assess its position an d develop a plan of action if it is determined it has a staffing problem. We recommend HUD assures the Authority: (1) develops procedures to distribute weekly activity reports to development managers and for development managers to use the weekly reports to manage their work order backlog; and (2) implements the use of performance standards to monitor staff performance. We recommend HUD and the Authority coordinate ot establish a target date to review the work order backlog, assess staffing needs, and develop a "get well" plan fi the backlog situation will result in less than a passing Public Housing Management Assessment Program grade. This review should be conducted no later than June 30, 1997. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Office of Inspector General Page 30 Chapter 4 Preventive Maintenance Previous HUD Office of Inspector General reports showed the Chicago Housi ng Authority lacked a comprehensive preventive maintenance program. HUD's Blueprint dated June 11, 1995, required the Authority to establish a summertime painting and cleanup program, replace the leadership of the operations staff, and implement a preventive maintenance program. In addition, the Au thority's draft Memorandum of Agreement dated June 21, 1996 contains strategies to: conduct a preventive nee ds assessment for each development and develop a plan for the funding and repair of deficiencies; determine who will perform the systems preventive maintenance inspections and repairs; and develop and implement a preventiv e maintenance schedule. HUD's Blueprint. In May 1995, HUD assume d Observations management of the Authority. In June 1995, HUD issued three preliminary strategies for the Maintenanc e Department in the Blueprint document. The Authorit y accomplished two of the three Blueprint strategies. First, the Authority established summer painting an d cleanup programs to increase the cleanliness an d appearance of the buildings and open spaces. Th e programs are collaborative efforts between the Authority , its residents, various City of Chicago departments, an d volunteers. Second, the leadership of the Operations Department wa s replaced in the Fall of 1995. A new Deputy Executiv e Director of Operations and a Director of Housin g Management were hired. Due to the condition of th e buildings and maintenance sy stems, the primary concern of the new Deputy Executive Director of Operations is t o address the regular maintenance activities. The Authority has not accomplished its third goal t o implement a comprehensive preventive maintenanc e program. The Authority did implement a preventiv e maintenance pro gram for its heating systems in May 1996. However, it does not have preventive maintenanc e programs for other mechanical systems or the units. Memorandum of Agreement. Two of the thre e Memorandum of Agreement strategies should have bee n completed by June 30, 1996. However only one wa s Page 31 Office of Inspector General Chapter 4 accomplished: the Authority has dete rmined which persons will perform the systems preventive maintenanc e inspections and repairs. The Authority did not conduct a preventive maintenanc e needs assessment for each of the devel opments and develop a funding plan for the repair of ma intenance deficiencies by the June 30, 1996 target date. The new Deputy Executive Director of Operations said the primary concern of th e Maintenance Department is to cond uct regular maintenance activities. He said it ha s been taking all of the maintenance staff's time to address work orders. Therefore, until th e work order level ca n be handled, a preventive maintenance program is beyond the Maintenance Department's presen t capabilities. While it is important for the Authority to concentrate it s efforts to address wo rk orders, it is equally important that a preventive maintenance program be developed. A n effective preventive maintenance progra m would detect and correct problems earlier , reduce the number of complicated and compounded repairs, and ease the staff's work orde r load. In addition, the early detection and correction o f problems would reduce repair costs and would provid e increased resources for additional maintenance staff . Therefore, it is important that the Authority implements a preventive maintenance program; however, the progra m cannot be developed until a preventive maintenance needs assessment is completed. The Deputy Executive Director of Operations did no t provide a target date for completing a preventiv e maintenance needs assessment. Instead, he said th e Authority has contracted for an authority-wide viabilit y assessment to be completed by December 31, 1996 . Although a viability assessment will show which buildings and systems are obsolete and which should be maintained, it will not provide the comprehensive information of a preventive maintenance needs assessment. A preventiv e maintenance needs assessment will identify wha t maintenance actions are necessary throughout the year t o adequately maintain systems. Office of Inspector General Page 32 Chapter 4 Until the preventive maintenance needs assessment i s accomplished, the Authority cannot determine the amount of money that will be needed to address the repairs. I n addition, the needs ass essment is necessary to complete the third strategy to develop and implement a preventiv e maintenance schedule by June 30, 1997. Therefore, it i s important that the Authority takes immediate action. We recommend HUD assures that the Authority completes its viability assessment by December 31, 1996 and immediately conducts or contracts to have a preventive maintenance needs assessment completed for each development and develops a funding planfor the repair of maintenance deficiencies. We recommend HUD assures that the Authority uses the preventive needs assessment to develop and implement a preventive maintenance schedule by June 30, 1997. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Page 33 Office of Inspector General Chapter 4 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 34 Chapter 5 Vacancy Reduction/Unit Turnaround Previous HUD reviews showed the Chicago Housing Authority did not have an effectiv e Vacancy Reduction/Unit Turnaround Program. The June 21, 1996 draft Memorandum o f Agreement between the Authority and HUD said the Authority had an adjusted vacancy rate in excess of 14 percent, and it averaged 137 days for unit turnaround. HUD issued a Blueprint dated June 11, 1995 requiring the Authority to accelerate its vacanc y reduction program. In addition, the Memorandum of Agreement established strategies to: (1 ) repair and re-occupy v acated units within an average of 30 days or less; (2) achieve an adjusted vacancy rate of four percent or less at a ll developments; and (3) reduce unit turnaround time and increase the agency-wide occupancy rate. Blueprint and Memorandum of Agreement. The Observations Authority has implemented a vacancy reduction progra m and has begun to implement the Blueprint an d Memorandum of Agreement strategies. However, th e Authority missed completing three key Memorandum o f Agreement strategies by the June 30, 1996 target date: (1) the Authority has no t tracked unit turn-around from date of vacancy to re-occupancy on a weekly basis; (2 ) implemented an automated reporting system to track vacant unit turnaround at the development level; or (3) identifie d and deprogrammed non-dwelling units. The Authority tracked vacant unit turnaround times fro m the dates of vacancy to re-occupancy on a monthly basis , rather than on a weekly basis. However, due to the length of time between reporting pe riods, monthly tracking of unit turnaround does not allow sufficient time to identify an d correct problems in order to achieve a 30 day uni t turnaround time. Unit turnaround time was not tracked on a weekly basi s because it was difficult and time consuming to gather th e information. The unit turnaround times were manuall y calculated for each developmen t using reports generated by the Authority's main computer s ystem. The reports showed the total number of vacancy day s during the month, and the total number of units re-occupied during the month at each development. However, the reports did not indicate th e following details: (1) the number of days units were vacant; (2) the time to repair each unit; or (3) the time it took t o Page 35 Office of Inspector General Chapter 5 occupy a unit after it was repaired. Without these details , the Authority did not have the capability to track each phase of the unit turnaround process. Therefore, when a delay in the unit turnaround process occurred, the Authority had no way to pinpoint which phase of the process caused th e delay. A new computer system, projected to be implemented b y December 31, 1996, should allow the Authority to trac k unit turnaround times on a weekly basis. In addition, th e new system will automatically calculate unit turnaroun d times, and it will generate reports that detail each phase of the unit turnaround process. Furthermore, a reportin g system to track unit turnaround at the development leve l will be implemented in conjunction with the new computer system. On July 16, 1996, the Deputy Executive Director o f Operations said the Authority had identified non-dwelling units at all of the developments except those under private management, and the Authority was currently in the process of identifying the non-dwelling units at the development s under private manag ement. Deprogramming non-dwelling units is an important step in develop ing a realistic picture of the Authority's vacancy rate. We recommend HUD assures the Authority implements weekly tracking of unit turn-around from the date of vacancy to re-occupancy and implements a reporting system to track vacant unit turnaround at the development level by December 31, 1996. We recommend HUD assures the Authority expeditiously identifies and deprograms all non- dwelling units. Repairing and re-occupying vacated units. The Memorandum of Agreement requires the Authorit y to repair and re-occupy vacated units within an average of 30 day s by December 31, 1 997. It is important for the Authority to meet a 30-day average turnaround time to provide th e maximum benefit of its scarce housing re sources to low and moderate income persons. Office of Inspector General Page 36 Chapter 5 The Authority hired a new Deputy Executive Director fo r Operations in October 1995. The June 21, 1996 draf t Memorandum of Agreement said the Authority average d 137 days for unit turnaround. This average reflected uni t turnaround times prior to when the new Deputy Executive Director was hired. The unit turnaround time consists of : the time required for repairs, the time a unit is vacant until repair work begins, and the time required to find a suitable tenant and reoccupy the unit. To evaluate the Authority's progress on repairing vacate d units for occupancy, since hiring t he new Deputy Executive Director, we selected 341 vacant units for which repai r work started between November 1995 and June 1996. We calculated the average time it to ok vacancy reduction teams to repair the 341 vacant u nits. Since the 341 units included units that were lo ng-term vacancies, we did not include the time from when the units were vacated until work began . We only calculated the time from when work actuall y started until the units were inspected and accepted by th e development managers. For the 341 units, it took th e vacancy reduction teams an average of 36 days to repai r each unit. Three factors that contributed to the 36 day average were: (1) lack of materials; (2) poor planning and scheduling; and (3) inadequate supervision. For example, at one of th e developments where vacancy reduction teams initiall y repaired units, materials needed to complete the repair s were not available when the teams arrived. As a result, the teams experienced "down time". In a ddition, poor planning and scheduling on the part of the Vacancy Reductio n Department also caused "down time". The vacanc y reduction teams were not given alternative wor k assignments while they waited for the needed materials . Finally, due to inadequate supervision, units completed by the vacancy reduction teams did not always meet HUD' s Housing Quality Standards. The vacancy reduction teams had to do additional repairs to the units th at did not meet the standards. The Vacancy Reduction Department has since established its own warehouse for materials and supplies to alleviate the lack of materials it was experiencing. In addition, th e Page 37 Office of Inspector General Chapter 5 Vacancy Reduction Department has improved its planning and scheduling procedures in order to minimize "dow n time". Finally the Vacancy Reduction Departmen t consolidated its vacancy reduction teams to improve th e level of supervision. These actions appear to have helped resolve delays i n repairing vacant units. For example, for units started an d completed during November and December 1995, it too k one development an average of 37 days to repair vacan t units. However, at the same development, it took a n average of only 26 days to repair vacant units started an d completed during May and June 1996. We did not assess whether these actions will assure that units repaired by the vacancy reduction teams meet HUD's Housing Qualit y Standards. We recommend HUD assures the Authority develops procedures to verify that units completed under the Vacancy Reduction Program meet HUD's Housing Quality Standards. To evaluate the Authority's progress on occupying vacan t units that were repaired by the vaca ncy reduction teams, we calculated the average time it took one Developmen t Manager to occupy 13 of the 341 units that were repaire d by the vacancy reduction teams. It took the Development Manager an average of 32 days to occupy a unit. Combining the average repair time with the time t o reoccupy repaired units shows the Authority is significantly exceeding its 30-day goal. The delay in occupying units was caused by a lack o f communication between the Vacancy Reductio n Department, Development Managers and the Occupanc y Department. The Vacancy Reduction Department did not give the Development Managers adv ance notice when units would be completed. Therefore, the units sat empty unti l the Development Managers and the Occu pancy Department could locate tenants to lease the units. Also, the Vacanc y Reduction Department did not coordinate with th e Occupancy Department to plan work to meet the greates t need. Office of Inspector General Page 38 Chapter 5 At one of the developments, the Vacancy Reductio n Department rehabilitated 49 units, but the Occupanc y Department did not have anyone on a waiting list. As a result, 36 of the units had been vacant for at least si x months. Allowing units to sit vacant increases th e opportunity for vandalism. As a result of sitting vacant, at least one unit at another development was vandalized an d required $1,315 in additional repairs before it could b e occupied. After we notified the vacancy reduction staff of th e communication problem , the staff implemented procedures to advise Developme nt Managers of the start and projected completion dates of repair work. Notifying th e Development Managers will resolve some of the problem; however, the Development Managers still need to provide projected completion dates to the Occupancy De partment so it can have people screened and ready to occupy the unit s when they become available. Al so, the Vacancy Reduction Department needs to coo rdinate its projected work with the Occupancy Department to ensure there will be a demand for the completed units. We recommend that HUD assures the Authority develops coordination procedures between the Vacancy Reduction Department, Development Managers, and the Occupancy Department. The procedures should ensure units are repaired on the basis of demand and applicable personnel areaware of projected completion dates so units can be promptly occupied. Vacancy Reduction Program goal. It appears the Authority may not reach the goal under its Vacanc y Reduction Grant to repair 2,857 units before it runs out of money. As of May 31, 1996, the Authority had completed 981 or 34 percent of the required units. However, it spent $13,769,237 or 46 percent of its Vacancy Reduction Grant. A possible explanation for the difference in the percentage of units completed and the percentage of dollars spent was the Vacancy Reduction Department did not prepare cos t estimates for all of the units it repaired. For example, out of 156 units that were in progress on June 25, 1996, cos t estimates could not be fou nd for 59. To determine whether the remaining grant money is sufficient to complete th e Page 39 Office of Inspector General Chapter 5 remaining 1,876 units, the Vacancy Reduction Department needs to prepare a cost estimate on each unit it intends t o repair. The Vacancy Reduction Department developed a revise d implementation schedule that showed the number of units it planned to complete at various developments. Th e schedule, however, did not detail which units would b e completed or contain a cost estimate for each unit . Consequently, we could not assess whether the schedul e was realistic. To provide some assur ance that the Authority will meet its goal to repair 2,857 units before it runs out of money, the Authority needs to implemen t a proper planning and budgeting process for the Vacancy Reduction Grant. We recommend HUD assures the Authority's Vacancy Reduction Department develops a plan that shows how it will complete the 2,857 units required by its Vacancy Reduction Grant. The plan should identify theunits that will be completed, and include the estimated costs for each unit. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Office of Inspector General Page 40 Chapter 6 Funding for Maintenance and Modernization The Chicago Housing Authority spends a large perc entage of its maintenance and modernization funding on security. Consequently, t he Authority's maintenance and modernization efforts have declined. Previous HUD reviews showed the Authority had not spent its l imited maintenance and modernization funding in a timely manner. As a result, the Authority failed the unexpende d funds component under the modernization indicator in the Public Housing Managemen t Assessment Program. The Authority established a strategy in it s Long-Term Plan, dated February 15, 1996, to develop a financial plan for funding maintenance and modernization efforts. The purpose of the plan is to find a way to spend m aintenance and modernization funding for its intended purpose and not on security. The Long-Term Plan listed four milestones the Authority should achieve throughout the period of the Plan. The milestones were designed to help the Authority stay on track towards implementing its strategy. In addition, the June 21, 1996 draft Memorandum of Agreement , which the Authority has committed to, listed four strategies the Authority should hav e implemented by June 30, 1996. The strategies were established to ensure the Authority meets the Memorandum of Agreement goal to continue to perform well under the modernizatio n indicator in the Public Housing Management Assessment Program. Long-Term Plan. The following milestones were listed in Observations the Authority's Lon g-Term Plan: (1) establish a committee to develop the initial plan; (2) perform a physical need s assessment of the buildings; (3) prioritize housing needs ; and (4) target and link up with appropriate resources. The Authority has begun working towards achieving two of the milestones, however, it has not started on the other two. The Authority is in the process of contracting with a firm to perform the physical needs assessment. The Authorit y expects to have the physical needs assessment of th e buildings performed by December 31, 1996. Also, th e Authority is prioritizing its housing needs. The Authority, however, has not established a committee to develop th e initial plan, and it has not begun to target and link up with appropriate resources. The milestone to establish a committee to d evelop the initial plan was scheduled to start in July 1996 and be completed by March 1997. On July 31, 1996, the Director o f Redevelopment was unaware of any committee bein g established. Although the Authority has until March 1997 to establish the committee and develop the initial plan, the Page 41 Office of Inspector General Chapter 6 Authority needs to establish a committee as soon a s possible to allow the committee sufficient time to develop the initial plan. The milestone to target and link up with appropriat e resources is not scheduled to start until April 1997, and i s not scheduled to be completed until December 2000. We recommend HUD closely watches the Authority's progress to establish a committee to develop the initial financial plan and to target and link up with appropriate resources. HUD should provide any technical assistance the Authority may require in order to achieve the milestones and implement the strategy. Memorandum of Agreement. To ensure the Authorit y will meet the goal in the Memorandum of Agreement t o continue to perform well under the modernization indicator in the Public Housing Management Assessment Program , the following strategies were established: (1) identify al l open modernization and capital improvement grants an d programs; (2) ensure that clearly defi ned responsibilities for project implementation schedules and expenditur e schedules exist between the Operations and Financ e Departments; (3) ensure that schedules are maintained i n accordance with HUD regulations; and (4) determine tha t the Authority's modernization and capital improvemen t programs are properly coordinated with the 1996-199 7 Comprehensive Grant Program plan. The Author ity met the June 30, 1996 target date for all the strategies except one. The Authority did not properly coordinate modernizatio n and capital improvement programs with the 1996-199 7 Comprehensive Grant Program plan . On July 31, 1996, the Director of Redevelopment said the Authority can no t complete this strategy until a viability assessment i s completed. The Authority is in the process of contracting with a firm to perform the viability assessment. Th e assessment is scheduled to be completed by December 31, 1996. We recommend HUD assures the Authority completes its viability assessment by December 31, 1996 and immediately coordinates its modernization and capital Office of Inspector General Page 42 Chapter 6 improvement programs with its 1996-1997 Comprehensive Grant Program plan. Unexpended funds. As stated above, the Authority me t the strategy to identify all open modernization and capita l improvement grants and programs. However, jus t identifying the open grants and programs does not provide any benefit to the Authority's residents or improve thei r living conditions. Delays in spending the grant mone y result in a lost purchasing power. In addition, the physical condition of the buildings continues to deteriorate, thu s requiring even more money. The foll owing table shows the grants and programs that were over three years old, an d were still open as of April 30, 1996. PROGRAM FUNDS UNEXPENDED YEAR NUMBER AS OF 4/30/96 1992 CGP - 7O1 $4,240,199 1992 IL2 - 163 $8,379,297 1991 IL2 - 922 $ 135,177 1990 IL2 - 921 $1,635,536 1990 IL2 - 920 $ 690,837 1987 IL2 - 915 $1,801,639 TOTAL $16,882,685 We recommend HUD works closely with the Authority to assure it closes out all of the open modernization programs related to the Comprehensive Improvement Assistance and Comprehensive Grant Programs that are over three years old. The Authority's Deputy Executive Director of Operation s Management's Comments said, "Regarding the Chicago Housing Authority's Long - Term Plan and Memorandum of Agreement, we concu r with the draft observations and associated r ecommendations and will incorporate same in our overall planning efforts." Page 43 Office of Inspector General Chapter 6 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 44 Chapter 7 Annual Inspections Previous consultant and HUD reviews reported that the frequency and quality of the annua l Housing Quality Standards inspections performed by the Chicago Housing Authority wer e inadequate. The draft Memorandum of Agreement dated June 21, 199 6 contains the following two long-term goals for the Authority that pertain to the annual inspections of the units and mechanical systems: (1) ensure that all housing units meet the City of Chicago hous ing code standards; and (2) inspect 100 percent of the housing units and systems annually. Memorandum of Agreement. The Memorandum o f Observations Agreement contains eleven short-term strategies t o accomplish its goals. Eight of the eleven strategies had a June 30, 1996 completion date. The remaining thre e strategies have future completion dates. Of the eigh t strategies with June 30, 1996 target dates, the Authorit y satisfactorily completed the following seven: • Revise and adopt City sanitary codes and incorporat e into HUD's Housing Quality Standards format. • Revise the Housing Quality Standards inspection form. • Train housing management and other Authority staff on unit inspections. • Train staff on work o rder priorities and which items are short-term, long-term, and emergencies. • Develop and implement procedures for inspecting one- tenth of units at each development on a monthly basis. • Determine if inspections and repairs will be site-based or a dedicated, central maintenance function. • Develop and revise existing reports to track and monitor unit inspections, inspection work orders, and the time to complete the work. The Authority did not complete the eighth strategy t o develop comprehensive inspection procedures. Written inspection policies and procedures. The Authority was in the process of revising its Maintenance Manual t o include policies and procedures for the annual inspections. However, the draft copy of the revised Maintenanc e Manual does not contain specific pro cedures for emergency situations identified during the annual inspections. I n Page 45 Office of Inspector General Chapter 7 addition, the Housing Quality Standards Training Manua l does not include thorough written procedures that th e inspectors need to know. For example, th e manual does not state how to complete the inspection form, how t o adequately describe the problem, or what procedures t o follow when an emergency repair is needed. To determine if the new procedures were being used, w e examined three annual inspection forms. One of the three forms, dated May 24, 1996, descri bed needed repairs for an inoperable smoke detector and a light fixture hangin g without adequate support. The Housing Quality Standards Training Manual identifies a light fixture hanging fro m electrical wiring without firm support as a hazardou s condition. However, a work order to repair a hanging light fixture was not recorded at that unit until June 21, 1996, 28 days after the inspection. It is important to have thorough inspection procedure s which address emergency situations becau se the majority of the staff who conduct the annual inspections ar e development clerks, site coordinators, and assistan t managers with little or no maintenance experience . Although the inspectors receive trainin g, written procedures reinforce the information taught, provide a reference source for future use, and help ensure inspectors un derstand that all emergency conditions need to be abated within 24 hours. We recommend HUD assures that the Authority develops thorough, comprehensive inspection procedures and includes the new procedures in the Maintenance Manual and Housing Quality Standards Training Manual. Future Memorandum of Agreement strategies. Three strategies have futur e completion dates. Two strategies are due to be completed on September 30, 1996, and the third strategy is due to be completed December 31, 1996. Th e three strategies pertain to the implementation of a job order contracting system to be used to per form maintenance work and for the annual inspection and repair of the majo r mechanical systems. Office of Inspector General Page 46 Chapter 7 The Authority plans to complete the Request for Proposa l evaluation process and select a vendor for a job orde r contracting system by September 30, 1996. However, the Deputy Executive Director of Operations said there are no funds remaining in the current year's budget to implement job order contracting. The Authority is in the process o f developing a new timetabl e for the implementation of a job order contracting system for mainte nance activities and will implement the system once funds are available in the next fiscal year. We recommend HUD assures that the Authority identifies the funds and implements a new timetable for initiating the job order contracting system. Once the timetable is complete, HUD should monitor the Authority to assure that the job order contracting system is properly implemented. In connection with our review of the Memorandum o f Agreement strategies, we determined that several areas not directly related to a strategy need attention. Annual uni t inspections were not a ll effective and work orders were not initiated for all necessary repairs identified by th e inspections. Housing Quality Standards inspections. The Authorit y performs annual Hou sing Quality Standards inspections on its units and systems. We examined three annual inspection forms that were completed afte r the new work order system was implemented on April 1, 1996 and found problem s with two of the three. One of the forms, dated May 24, 199 6, showed that the unit failed in two areas; however, the unit was given an overall pass rating. The annual inspections are used to assess th e conditions of the units. When units with violations tha t should cause it to fail the inspection are passed , management does not have an accurate assessment of th e unit conditions. An accurate assessment is essential t o determine and plan the long-term modernization needs o f the Authority. On the second form, 38 fail conditions were noted . However, the form did not describe any of the neede d Page 47 Office of Inspector General Chapter 7 repairs. The inspectors' descriptions of the needed repairs are used by technicians at the Customer Service Center t o create work orders. Without a proper description of th e deficiencies, the technicians cannot determine the type o r magnitude of repairs required. Additionally, maintenance superintendents do not have a sound basis to order materials or schedule craft personnel. The revised Maintenanc e Manual recommends that maintenance superintendent s verify the quality of repairs made; however, it does no t require superintendents to verify that the inspections were properly conducted and inspection forms properl y completed. Without proper quality control over th e inspections, the Authority lacks assurance that inspections are properly completed and unit conditions are correctl y rated. We recommend HUD assures the Authority conducts quality control reviews of inspections to ensure the inspections are accurately conducted and inspection forms are properly completed. Housing Quality Standards work orders. The Authority implemented a new, computerized and integrated wor k order system on April 1, 1996 to provide better control and accountability over work orders. The system module s allow the Author ity to monitor the progress of the Housing Quality Standards inspections and the status of th e inspection work orders. However, inspection work orders were not generated for all repairs. As previously stated, three Housing Quality Standard s inspection forms, completed after April 1, 1996 wer e reviewed. One of the three forms, dated May 24, 199 6 indicated that repair problems existed in 38 areas at on e unit. A work order history report was obtained of the repair activity at that unit since the new work order system wa s implemented. No work orders were entered into the ne w work order system for any problems or repairs at the unit. A second of the thre e inspection forms, also dated May 24, 1996 indicated a hazardous electrical condition at the unit. The work order history report for that unit contained on e work order, dated June 21, for an electrical repair . However, we were not able to determine whether the repair Office of Inspector General Page 48 Chapter 7 was for the problem reported on the inspection for m because the repair was made in a different room. To conduct efficient and effective repairs at the units, it is important for work orders to be generated expeditiously to ensure that repairs are performed time ly. We contacted two development managers concerning the annual inspectio n forms completed after April 1, 1996. Each of the managers said the inspection forms were not sent to the Custome r Service Center so work orders could be written. Instead , the inspection forms were being held at the developmen t until Customer Services requested them. We recommend HUD assures the Authority promptly evaluates each development to determine if all annual inspection forms, completed after April 1, 1996 were sent to the Customer Service Center to initiate work orders. We recommend HUD assures the Authority implements controls that ensure work orders are written to address deficiencies identified by all future inspections. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Page 49 Office of Inspector General Chapter 7 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 50 Chapter 8 Housing Management Functions Previous HUD and consultant reviews showed the Chicago Housing Authority: had a large and loosely structured middle management; was unable to implement management controls an d maintain a system of quality control; and used a highly centralized and controlled system fo r decision making, which limited its capacity to effectively pursue and realize the benefits of a more decentralized and site based management structure. These organizational deficiencie s inhibited the Authority's ability to effectively manage its programs. To correct the organizational deficiencies, the Authority established a goal in its Long-Term Plan dated February 15, 1996 to: improv e coordination and accountability between the development- based operations and the central office; an d provide good housing management. In addition, the Authority and HUD established two goals in the Memorandum of Agreement, dated June 21 , 1996, to: improve organizational a ccountability; and streamline housing management efficiency and effectiveness. Long-Term Plan. To ensure the Authority met the goal to Observations improve coordination and accountability betwee n development-based operations and the central office, th e Authority established the following strategies: (1 ) implement development-based resource management; (2 ) develop and review uniformed field-based policies an d procedures; and (3) develop a uniformed propert y management reporting process. The Authority has unti l December 31, 2000 to implement these strategies. Base d on our assessment, the Authority will easily meet this target date. Development-based resource management. The Authority was taking the appropriate steps towards implementing the development-based resource management strategy . Specifically, the Authority was in the process of contracting with a consulting f irm to perform a skills assessment of the property management staff by January 31, 1997. Th e assessment will enable the Authority to identify th e strengths and weaknesses of its property managers. Also, the Authority plans to have a new computer syste m installed by December 31, 1996. The new system wil l connect each development to the central office, thu s strengthening the communication link between the two . Finally, the Authority was in the process o f contracting with an institution to train its staff on the development-base d budget process by December 31, 1996. The training i s Page 51 Office of Inspector General Chapter 8 needed so the Authority can effectively implement th e development-based budget process in fiscal year 1997. Field-based policies and procedures. The Authority wa s also taking appropriate steps towards the development and review of uniform field-based policie s and procedures. The Authority identified and reviewed Authority-wide policies and procedures that impacted housing operations. I n addition, the Authority developed and was implementin g new policies and procedures. For example, the Authorit y developed and implemented a new lease and new tenan t screening procedures (see Chapter 9). The Authority also revised its eviction procedures (see Chapter 9), and was in the process of developing and implementing a ne w maintenance manual (see Chapter 3). The Director o f Housing Management said the Authority will continue t o monitor and evaluate policies and procedures that impac t housing operations, and to develop and implement ne w policies and procedures as necessary. Property management reporting process. The Authority had substantially developed a uniform property managemen t reporting process. The Authority determined that dat a related to the following categories should be reported : tenant accounting, housing eligibility, and work orders . Examples of specific repo rts that will be generated include: tenant accounts receivables, tenant demographics , outstanding work orders, unit turnaround times, and tria l balances of general ledgers. The Authority's new computer system will collect the relevant data and generate thes e reports. The Authority established monthly, quarterly , semi-annual, and annual time frames for the reports to b e submitted. We recommend that HUD monitors the Authority's progress in completing its Long-Term Plan strategies to: implement development-based resource management; participate in the development and review of uniform field-based policies and procedures; and develop a uniform property management reporting process. Should the Authority deviate from the Long-Term Plan strategies, HUD should provide technical assistance or take other corrective actions. Office of Inspector General Page 52 Chapter 8 Memorandum of Agreement. The Memorandum o f Agreement contains two strategies related to a development-based resource management/propert y management reporting system. The two strategies are : improve communications and internal reporting betwee n the site managers and the central office; and create site - based management implementation plans for eac h development. The draft Memorandum of Agreement also incorporates the Long-Term Plan goal and strategies to provide goo d housing management into nine major strategies t o streamline housing management efficiency an d effectiveness. The strategies are: identify existing majo r housing functions, establish evaluation procedures an d criteria, evaluate the functions' cost effectiveness an d efficiency, do a cost benefit analysis of the functions , identify required changes nece ssary to improve the housing management functions, document the changes necessary to improve housing management functions, implement th e changes, develop methods to fill gaps in housin g management functions, and identify opportunities t o delegate management functions to the developments. The Memorandum of Agreement target dates fo r completing the nine strategies to improve housin g management ranged from June 30, 1996 to December 31 , 1997. With the exception of the strategy to delegat e management activities to the developments, the strategie s form a series of steps that identify all major housin g functions needed; measure and evaluate th ose functions that are in place; and identify and implement needed change s and improvements. Communications and site-based m anagement. The strategy to improve communications and internal reporting has a June 30, 1997 tar get date. This strategy corresponds to the Long-Term Plan strategies mentioned above. As state d previously, the Authority has initiated actions that shoul d allow it to complete this s trategy on schedule. The strategy to create site-based management implementation plans has a target date of December 31, 1997. As of August 26 , 1996, the Authority had not begun action to complete this Page 53 Office of Inspector General Chapter 8 strategy; however, the Authority has sufficient tim e available to complete the strategy on schedule. We recommend HUD closely watches the Authority's progress in implementing the Memorandum of Agreement strategies to: improve communications and internal reporting between the site managers and the central office; and create site-based management implementation plans for each development. HUD should provide any technical assistance the Authority may require to assure the strategies are implemented on schedule. Improvement of Housing Management Functions. The Memorandum of Agreement required the Authority t o identify all major housing functions by Septem ber 30, 1996. As of August 30, 1996, the Authority identified th e following six areas related to the maintenance housin g function: custodial, elevators, vacancy preparation , mechanical, heating plant, and contract maintenance. The Authority is using staff meetings to identify managemen t functions and ways of improving them. Although th e Authority identified the maintenance housing functions by the September 30, 1996 target date, it needs to identif y areas within the other major housing functions such a s occupancy, accounting, security and redevelopment. Th e Director of Operations said the Authority was in the process of identifying other housing functions and that the strategy is on-going and w ill continue after the September 30, 1996 target date. It is important for the Authority to identify all areas a s quickly as possible, since the information is required t o accomplish the strategies with later target dates. We recommend HUD and the Authority coordinate ot establish a revised target date to identify all major housing functions and that HUD assures the Authority allocates sufficient resources to accomplish this strategy. The Authority deve loped evaluation criteria for each of the six areas identified under the maintenance function. It also started evaluating the cost effectiveness and efficiency o f the six areas and d oing a cost benefit analysis of two of the Office of Inspector General Page 54 Chapter 8 areas. For example, the Authority established evaluatio n procedures and criteria for the custodial and heating plan t functions. It compared the costs associated with performing the functions in-house to the costs of contracting them t o private firms. The Authority analyzed: staffing levels , salary and other costs, scope of services, and cost s associated with contracting the functions to private firms . Evaluating the cost effectiveness and efficiency establishes a basis for the best performance of the function in-house , while a cost benefit analysis compares the Authority's cost to perform its functions to outside sources. The completion of the later strategies in the Memorandum of Agreement all depend on the Authority timel y identifying all major housing functions, evaluating cos t effectiveness, and doing a cost benefit analysis. Th e strategies to identify needed changes, document th e changes, implement the changes, and develop methods t o fill gaps in functions due to be completed December 31 , 1997, depend on the timely completion of the earlie r strategies. We recommend that HUD closely monitors the Authority's progress to meet the housing management improvement strategies and provides any assistance necessary to help evaluate the functions, and improve their effectiveness and efficiency. Delegation to Developments. The Memorandum o f Agreement required the Authority to identify opportunities to delegate management activities to developments by a June 30, 1996 target date. The Authority identified an d delegated purchasing functions to all developments an d delegated management of 23 developments to privat e managers. In addition, the Authority's Long-Term Pla n requires site-based management impl ementation plans to be completed; however, it has not begun to complete thi s strategy. On March 1, 1996, the Authority delegated procuremen t functions related to open purchase orders to th e developments. The open purchase order system allow s development personnel to obtain supplies and materials at Page 55 Office of Inspector General Chapter 8 designated hardware stores subject to established dolla r limits. On July 1, 1996, the Authority placed about 8,000 units at 23 developments under private management. Fiftee n private firms are in charge of day-to-day operation s including leasing, maintenance, property management and security, along with fiscal management of th e developments. The Authority met its goal of identifying opportunities t o delegate management activities; however this is a poorl y worded strategy. As the Authority continues to change, it needs to identify additional opportunities to delegate to the developments when it makes economical sense. We recommend HUD and the Authority coordinate ot make the strategy a continuing effort. Although the Memorandum of Agreement contains th e strategy to delegate management activities to it s developments, it does not have a strategy to review th e results of its actions in the future to ensure they ar e effective and achieve the expected results. We recommend that HUD and the Authority coordinate to establish a strategy to review the results of actions taken to delegate responsibilities to the developments. We suggest a review be conducted approximately one year after a responsibility is delegated. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Office of Inspector General Page 56 Chapter 9 Admissions and Evictions A previous HUD Office of Inspector General report said the Authority did not admit and evict tenants in a consistent manner to assure problematic tenants were not allowed into housing o r were promptly rem oved. The Authority did not: have an adequate written policy; use standard procedures; and adequately communicate information to development managers. As a result , problematic residents were admitted or not evicted which increased related maintenance an d security costs. The Authority's draft Memorandum of Agreement with HUD and its Long-Term Plan contai n goals to improve the Authority's admis sions and evictions procedures. To achieve the goals, the Authority developed strategies to improve tenant screening, eviction procedures, leas e procedures, and promote resident responsibility. Screening procedures. The Authority revised its resident Observations screening procedures in order to provide assurance tha t persons admitted to it s housing are eligible and are suitable residents. The procedures were issued on October 16 , 1995. The Authority's new screening procedures requir e home visits, landlord verifications, and credit and security checks. These procedures wer e implemented on March 15, 1996. The first 100 home visits are being completed by a n independent contractor. As of June 25, 1996, 88 hom e visits were completed. The Authority plans to hire tw o inspectors to conduct home visits. Position description s have been developed and were approved on July 15, 1996. Once the positions are included in the Occupancy budget, the jobs will be p osted. It is unlikely that the two positions will be filled before the remaining 1 2 contractor inspections are completed. To ensure new tenants are properl y screened, the Authority will have to extend its home visi t contract until the positions are filled. We recommend HUD assures the Authority fills its home visit inspector positions as expeditiously as possible. We recommend HUD assures the Authority extends its contract to conduct home visits until it fills the home visit inspector positions. Page 57 Office of Inspector General Chapter 9 The Authority's current waiting lists are unmanageable . The Authority has a registrant pool of approxi mately 30,000 applicants. As of July 15, 1996, the Autho rity did not know the eligibility status or interest of i ts registrant pool, but was working to contact each applicant to determine their status. The Authority closed the waiting list pending its review of the 30,000 and the manageability of the list. In addition to the registrant pool, t he Authority prepared certified waiting lists by unit size for eligible applicants that have bee n screened. For example, the certified family waiting lis t contained approximately 1,200 applicants. In order for the screening procedures to be effective, the y must be performed as close to the time of occupancy a s possible so information gathered is current. As of July 15, 1996, the Authority was screening all registrant poo l applicants according to the date and time of thei r applications regardless of when they will be offere d housing. Additionally, the Authority had no plans to screen applicants who were on certi fied waiting lists before March 15, 1996 and had not been screened according to the ne w procedures. Only 55 applicants on the family waiting lis t have been screened u sing the new procedures and most are toward the end of the waiting list. The Authority place s approximately 172 family applicants in a month; however this not a good gauge on how long a family may have t o wait for housing. For example, families who a re waiting for units at Leclaire Courts, Lake Parc Plac e and Trumball Park Homes can expect to be on the waiting list for one, four and ten years respectively. As a result, many certified waiting list applicants may be offered housing without prope r screening for years to come. When we discussed thi s observation with the Director of Occupancy, he said th e Authority would start screening al l applicants that are being considered for immediate occupancy regardless of any past screening that may have been accomplished. The Authority is wasting staff resources screenin g applicants who may wait for years to be admitted or wh o may not be admitted at all. The determination o f preliminary eligibility should be based upon informatio n and supporting documentation provided by the applicant . There is no need for detailed checks or v erifications until an applicant is being seriously considered for occupancy. For Office of Inspector General Page 58 Chapter 9 most of the applicants who have been screened using th e new procedures, the results of the third-party verifications, home visits, credit and security checks will be outdate d when units become available. Therefore, screening wil l have to be reaccomplished. To conserve scarce resources, it is important to screen tenants as close to the projecte d date of occupancy as possible. Also, in order for th e Authority to fulfill tightene d standards on selecting suitable tenants, it is extremely important that all new tenants b e screened using the new procedures bef ore they are admitted to a unit. We recommend HUD assures the Authority develops procedures that ensure all applicants are screened using the new screening procedures beforebeing placed in a unit. The procedures should state that applicants will not be screened upon initial interview if units are not available and that screening should be conducted as close to the time of occupancy as feasible. Current Occupancy personnel have interpreted th e Gautreaux Court Decree to allow applicants to continually refuse offers of housing not of their preference. Th e applicants' refusals do not change or negatively effect th e applicants' positions on the waiting list. There is essentially no limit to the number of times applicants can deny unit s not of preference or change preferences. As a result , applicants may remain on the waiting list for years . Additionally, our discussions with the Authority' s Occupancy personnel indicated they were not clea r concerning the actions to be taken when applicants den y housing offers of their preference and were confused o n when applicants are allowed to change their location o f preference. The s taff did not have a legal opinion to use in formulating its waiting lists and had not requested one. To help resolve the waiting list problem, the Authorit y contracted with Creative Computer Solutions Systems t o devise and implement a com puterized waiting list. Initially, the Authority projected the waiting list would be full y operational on August 1, 1996. However, this target dat e may not be realistic. As of July 16, 1996, the consultan t was in the process of converting the data. Additionally, our discussions with the consultant indicated she was confused by the terms of the Gautreaux court decree and how it will Page 59 Office of Inspector General Chapter 9 affect the creation of waiting list reports. Once conversion is completed test rep orts need to be run to ensure accuracy. Personnel operating the occupancy program and developing the computerized waiting list need to have a thoroug h understanding of the Gautreaux decree in order to develop and use acceptable waiting lists. We recommend HUD assures the Authority coordinates efforts with HUD's and its legal department to provide a consistent application of the Gautreaux decrees' requirements. Guidelines supporting interpretations should be developed and application of the computerized waiting list should reflect the guidelines. Eviction procedures. It is the Chicago Housin g Authority's policy to no longer tolerate re sidents who do not pay their rent, obey Authority rules, and contribute to their community. Communication and coordination between the Development Management and Tenant Relation s departments has improved since the OIG review that wa s completed on January 14, 1994. The Authority's staff have been trained on the Authority's ev iction procedures for both "delinquent rent" and "for cause" evictions. The Authority is aggressively pursuing resident evictions. For example , the eviction of substance abusers who qualified for senio r housing because they were considered to be disabled ha s increased, and the in creased emphasis of evictions for non- payment of rent has decreased delinquencies. Effective June 1995, the Authority amended its evictio n policy for senior housing because of changes in HUD' s regulations. Senior housing residents not only includ e senior citizens, but handicapped a nd disabled (drug addicts; alcoholics) individuals. During all of 1995, the Authorit y evicted 41 residents from senior housing. During the first six months of 1996, the Authority has already evicted 3 6 residents from senior housing. The majority of thos e evicted were substance abusers. Rent delinquencies have dramatically decreased . Beginning in November 1995, the Authorit y changed its procedures to require hand delivery of the 14-Day Notice of Termination for non-payment of rent. The Authority aggressivel y pursued residents with delinquent balanc es regardless of the Office of Inspector General Page 60 Chapter 9 amount or length of time past due. Cases were filed an d individuals were prosecuted. These actions sent a stron g message to residents that they can and will be evicted fo r non-payment of rent. As a result, the number of 14-Da y notices generated fell from 1 ,542 in November 1995 to 578 in June 1996. In connection with improving eviction procedures, th e Authority developed a strategy to coordinate evictio n efforts with the Divi sion of Resident Programs. This effort was needed because of concerns that residents wit h delinquent rent balances, who were otherwise in goo d standing, could be evicted without consideration of special circumstances. For example, a mentally ill resident or a victim of domestic violence, may face s pecial problems that could effect their ability to pay their rent timely. Th e coordination effor ts were implemented informally between Development Managers and the Au thority's Social Services Division. Development Managers and the Social Service s Division work together to refer applicable residents to th e appropriate agencies for assistance. However, forma l procedures need to be developed to ensure all manger s follow the same process and tenants are treated equally. We recommend HUD assures the Authority develops procedures for Development Managers and the Social Services Division to coordinate on potential evictions and the need for social services. Lease Procedures. The Authority's resid ential lease details responsibilities and obligations of the residents an d describes specific actions which may result in a tenant' s eviction. The Authority approved a new lease on June 21, 1996. The Authority amended the old lease to include a provision that allows the Authority to evict residents wh o have been served four 14-Day Notices of Terminatio n within a 12-month period. The Authority's prior lease did not contain a provision limiting the number of Notices o f Termination received during a year. Also, the lease wa s changed to require residents between the ages of 7 and 16, living in the households, to attend school in accordanc e with the Authority's truancy policy. Leaseholders can b e evicted if this provision is violated. The new lease wil l Page 61 Office of Inspector General Chapter 9 enable the Authority to hold r esidents more accountable for their actions. The Authority's Memorandum of Agreement established a target date of June 30, 1996 for the lease to be revised . Although the Aut hority met this goal, it did not include the following Public Housing Notice 96-14 provisions, issued on April 1, 1996, in the revised lease: (1) the lease may be terminated if a resident's abuse of alcohol interferes with the health, safety, or right to peaceful enjoyment of th e premises by other residents and employees; and (2 ) grievance proceedings may be w aived for any non-criminal activity that interferes with the health, safety, or right t o peaceful enjoyment of the premises by other residents and employees. We informed the Authority's staff of th e omission. The staff said they will amend the lease t o include the provisions. Lease training is mandatory for all Development Managers, including private and resident management staff. Leas e training was conducted by the Tenant Relations Divisio n during the month of July 1996 for all development staff . Resident lease training i s scheduled to be conducted during August and September 1 996. Resident training is optional. The training offered will model the staff's training . Residents who choose not to attend the training, will b e briefed on the lease requirements when they sign a ne w lease. The residential lease wil l be implemented once training has been completed. New residents will be admitted under the requirements of the new lease. The Authority will operate under two leases for approximately one year, since th e Authority cannot require current residents to sign th e revised lease until their annual recertifications. We recommend HUD assures the Authority's lease contains the correct provisions outlined in Public Housing Notice 96-14 and the Authority uses the lease. We recommend HUD assures the Authority completes lease training for all residents by September 30, 1996, and upon approval, uses the lease for all new tenants and for all annual recertifications. Office of Inspector General Page 62 Chapter 9 Resident responsibility. The Chicago Housing Authority has drafted a tenant handbook. The handbook details th e rights, privileges, and responsibilities of the resident. The new handbook has updated telephone numbers and is less cumbersome than the old one. The tenant handbook ha s been approved by the development staff and residen t leaders. As of July 8, 1996, the draft was awaiting th e approval of the Chicago Housing Authority's senior staff . The Long-Term Plan' s target completion date is September 30, 1996 for the approval of the handbook. The Authority appears on track to meet this goal. The Authority plans to distribute the new handbook to al l new residents; however, it had no plans to get copies t o current residents. Since the new handbook has revise d information and is less cumbersome, we believe it shoul d be given to all residents. We recommend HUD assures the Authority makes the new handbook available to all residents when they recertify their leases. After the Authority completes the tenant handbook, leas e training, and lease implementation, it plans to develop a site-based resident orientation process and manual. Th e orientation process and manual will inform residents o n their rights and responsibilities; the tenant handbook; th e Authority's rights and responsibilities; lease requirements; house rules; safety and security issues; and procedure s followed when lease violations occur. The Memorandu m of Agreement's target date fo r completion of the orientation manual is September 30, 1996 and December 31, 1996 for the orientation process. The target dates appear realisti c and the Authority has sufficient time to meet these goals. We recommend HUD assures the Authority adoptsa tenant handbook and develops the site-based resident orientation manual by September 30, 1996, and implements a site-based resident orientation process by December 31, 1996. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Page 63 Office of Inspector General Chapter 9 Housing Authority will incorporate the offere d recommendations in our overall planning process." Office of Inspector General Page 64 Chapter 10 Rent Collections HUD's past performance reports showed the Chicago Housing Authority's history in collecting rents was inadequate. The Authority did not have a col lection agency, and rents were not always collected. Thus, the Authority lost a source of income. To remedy this, HUD and the Authority included a goal i n its June 21, 1996 draft Memorandum of Agreement to maintain a six percent uncollected rent rate at all developments. Uncollected Rents. The Chicago Housing Authority' s Observations uncollected rent balance has consistently been excessive . As of December 31, 1995, 9.6 percent of resident dwelling rents were uncollected. After one quarter under the March 6, 1996 draft Memorandum of Agreement, rent s uncollected were reduced to 8.2 percent. The Authorit y used the March 6, 1996 draft Memorandum to monito r progress for this initiative. Orientation Programs. To promote and improve th e timeliness of tenant payments, the Authority ha s coordinated with various service agencies to conduc t orientation progr ams for its residents. The Authority had a Memorandum of Agreement target date of September 30 , 1996 to begin initiating urban life style programs. Thes e programs include: managing and supervising children , money management, interrelationships in an urban setting, and community identification and commitment. Th e Authority met this target date. For example, on May 2 and June 18, 1996 a local bank made presentations to residents that covered payment of rents at currency exchanges , money managem ent, and credit repair. On April 30, 1996, a local utility company made a presentation on conserving energy and establishing budget plans for bill payments . The orientation programs are an on-going effort that ar e intended to increase the tenant's skills in managing thei r financial affairs and their understanding of the importance of timely payments. Development of Partnerships. In accordance with th e Memorandum of Agreement's September 30, 1996 targe t date, the Authority developed partnerships with variou s publicly supported service agencies to help preven t evictions of tenants who have no income, for non-payment of the minimum rent requirements. HUD now requires all Page 65 Office of Inspector General Chapter 10 residents to pay a minim um rent of $25 a month. Based on this requirement, the Authority has approximately 1,50 0 tenants who report zero income and will need assistance to make the minimum monthly rent payment. The Authority pursued outreach efforts with socia l services/delegate agencies and received their agreement to help obtain assistance for tenants who can not mee t minimum rental requirements. For example, the Authority established relationships with th e Partner in Human Service Delivery Agency, the Social Security Administration, th e Illinois Department of Public Aid and local churches . These agencies are both publicly and privately funded. The agencies plan to assist persons in obtaining supplementa l income and guidance to meet financial requirements. In August 1996, the Authority started referring all tenant s who apparently have no source of income to the agencies. We recommend HUD assures the Authority continues to develop sources for orientation programs and financial services to assist its tenants to become more self sufficient. HUD should provide assistance in identifying and developing the sources. Collection Agency. In December 1995, the Authorit y advertised for a collection ag ency to provide rent collection services for tenants who no longer reside in the Authority's developments. The first Request For Proposal did no t generate any responses. The Authority advertised again on January 22, 1996. The second request received on e response. Since the Authority had contracted with the firm in the past and was satisfied with its performance, th e Authority executed a contract with the firm on July 11 , 1996. The Authority is in the process of sending out notices t o former tenants regarding their delinquent accounts. Th e notices request the former te nants to make payments within five days or accept a payment plan. Former tenants who do not respond will be referred t o the collection agency. As of August 1, 1996, the Author ity had not referred any cases to the agency. The Authority plans to start referring case s Office of Inspector General Page 66 Chapter 10 after it reviews and processes its August 1996 tenan t accounts receivable report. We recommend HUD assures the Authority establishes controls to ensure all uncollectible accounts are referred each month to the collection agency. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Page 67 Office of Inspector General Chapter 10 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 68 Chapter 11 Procurement and Contracting Previous HUD, ind ependent public accountant, and consultant reviews of the Chicago Housing Authority showed the Authority did not have an effective procurement program. Specifically, the reviews concluded the Authority did not procure items in a timely manner. The Authority also lacked an adequate contracting process in the past which allowed for favoritism, produc t substitution, and services not being provided. The Authority's draft Memorandum of Agreement, dated June 21, 1996, contained strategies to meet the goal of streamlining, stand ardizing, and automating the procurement process necessary to maintain a continuous flow of quality, material supplies and services related to outstandin g work order deficiencies. While the goal specifies problems related to outstanding work orders, the strategies developed are designed to improve the overall procurement process. HUD' s Blueprint, dated June 11, 1995, the Authority's Long-Term Plan, dated February 15, 1996, and the Memorandum of Agreement did not include any goals or strategies relating to the Authority's contract process. Memorandum of Agreement strategies. The Authority's Observations Memorandum of Agreeme nt contains strategies to improve the procurement process. If the Authority follows through and fully implements the strategies, the Authority wil l significantly improve the procurement process and it s timeliness. The Authority is currently on schedule t o complete improvement of the procurement process b y March 31, 1997. However, the Authority did not hav e sufficient control over its procurement proc ess used to abate emergency conditions and purchases on i ts open supply and service accounts. Process to abate emergency conditions. The Memorandum of Agreement required the Authority t o develop a process to abate emergency conditions by Jun e 30, 1996. The Authority established an unwritten process. The Maintenance Advisor said each maintenanc e superintendent is aware of the emergency procuremen t process; however, the Authority has not included th e process in its Maintenance Manual. The unwritte n procedure requires maintenance superintendents to follow a specific sequence to obtain materials to c orrect emergency conditions. The superintendents must: (1) check th e emergency stock room at the development's maintenanc e office; (2) check the satellite warehouses; (3) check th e main warehouse; (4) use the open supply and servic e Page 69 Office of Inspector General Chapter 11 accounts; or (5) obtain an emergency check to direc t purchase materials from any available supplier. We contacted the maintenance superintendents for th e following developments: (1) Altgeld Gardens; (2) Stateway Gardens; (3) Francis Cabrini Homes; (4) Robert Taylo r Homes B-2; and (5) Ida B. Wells Homes. The maintenance superintendents said they were aware of the procurement process. Because of the conversion to a new computer system, we were unable to determine if the superintendents followed the procurement process. W e could not determine if the items obtained through the open hardware accounts were available in the Authority' s warehouse at the time of purchase. However, we di d identify the purchase of non-emergency items, such as , landscaping bark and flower s eeds; therefore, it appears not all superintendents followed the correct process. On June 30, 1996, the Authority was in the process o f rewriting its Maintenance Manual. The revise d Maintenance Manual is scheduled to be completed b y August 1996. It is important that the revised manua l include written procedures to formally outline th e Authority's emergency procurement process. Writte n procedures help eliminate subjectivity and provid e consistency to the process. We recommend HUD assures the Authority establishes written procedures outlining the emergency procurement process and incorporates the procedures in the Maintenance Manual. Open supply and service accounts. In January 1996, the Authority established purchase agreements for ope n hardware accounts with various vendors for it s developments and departments. The accounts wer e established to assist the Authority in procuring emergency items not on hand in its warehouse system. The purchas e agreements detailed the: (1) maximum monthly and annual spending limits; (2) Authority 's staff authorized to purchase items; and (3) discounts the Authorit y should receive on the purchases. Office of Inspector General Page 70 Chapter 11 We reviewed 37 items purchased from two of th e Authority's vendors during March and April 1996. Th e items had been approved and forwarded for payment. The Senior Manager of Finance for Public Housing and Private Management, and the Director of Housing Manage ment had responsibility for reviewing and approving the invoices ; however, they did not require ve rification of the emergency condition. Instead, they relied on the discretion of th e purchasing officials. There was no reference on th e supporting invoices or any attached documentation tha t showed the items were purchased for emergency purposes. We attempted to determine the status of the i tems purchased but could not find any documentation, such as th e emergency work order or work order number, that showed the purchases were for emergencies. Items purchase d through the open supply accounts are generally mor e expensive than those purchased centrally because th e purchases are usually in small quantities and not subject to quantity discounts. Therefore, verification of emergenc y purchases is necessary to help prevent waste and abuse. We recommend HUD assures the Authority establishes procedures and controls to verify that items purchased through the open hardware accounts are for emergency purposes. The Authority stayed within its spending limits, and onl y authorized personnel purchased items; however, th e Authority did not receive all of its purchase discounts. The Senior Manager was not aware discounts were to b e received because he was not notified of the terms of th e agreements by the Purchasing and Contracts Departmen t who established the purchase agreements. However, even if he was aware of the disco unts, he could not have verified them, since the vendor invoices did not always disclose the original price and the discount. Twe nty-one of the 37 items reviewed were purchased from one vendor . We determined the Authority did not receive the 5 percent discoun t required by the purchase agree ments for 18 of the 21 items. Following are examples of discounts lost: Page 71 Office of Inspector General Chapter 11 Item List Price Discount Price Paid Lost Steel $119.99 $119.99 $6.00 Bathtub Cordless Drill 46.99 46.99 2.35 Padlock 16.99 16.99 1.70 For the three items where the Authority did receive it s discount, the list price and the price charged were shown on the charge slips which would ha ve allowed the Authority to verify the discount. Although the total lost discounts w e identified were small, the Authority should have a method to verify the accuracy of discounts. Additionally, as these purchase agreements are used more, the potential loss from foregone discounts will increase. For example, one vendor was providing discounts of between 15.01 and 47.2 5 percent depending on the item. One purchase agreement incorrectly showed the Authority was not entitled to a discount. However, the vendor wa s giving the Authority a discount. The vendor had othe r agreements with the Authority to provide supplies at a discount and extended the practice to the open supply and service account. It is important that the purchas e agreements accurately reflect the discounts in order t o protect the Authority's interests and provide managemen t officials correct data for their review of transactions. We recommend HUD assures the Authority implements procedures to notify reviewing officials of the terms of the open supply and service accounts' purchase agreements. We recommend HUD assures the Authority requires its vendors to show discounts received on applicable invoices so the Authority has assurance it is receiving the discounts to which it is entitled. Office of Inspector General Page 72 Chapter 11 We recommend HUD assures the Authority reviews its purchase agreements to ensure they reflect the correct discounts. With the impleme ntation of controls to verify if a purchase is an emergency and to verify the ac curacy of discounts, we believe the strategy to identify opportunities for ope n supply and service accounts will be satisfied. We recommend HUD closely watches the Authority's progress in implementing the strategies for improving the procurement process by March 31, 1997. HUD should provide any technical assistance the Authority may require in order to achieve the goal and target date. We recommend after all strategies have been implemented, HUD assures the Authority assesses its procurement process to ensure the problems the strategies were created to eliminate have been corrected or takes actions to make additional changes. This should be accomplished by September 30, 1997. Contracting process. In the past, the Authority' s contracting process was not adequate which allowed fo r favoritism, product substitution, and services not bein g provided. For example, the Authority's contracting process did not, at a minimum, require that bid sheets b e maintained, contract solicitations be advertised, an d contract files be maintained. The Authority's failure t o maintain an adequate contracting process also allowed for manipulation by former Authority employees. The Director of Purchasing and Contracts took over th e Department in July 1994 and initiated actions to correc t prior contracting proble ms. For example, the Director now requires that: (1) bid sheets be maintained; (2) contrac t solicitations be advertised in local and nationa l publications; and (3) file sheets be maintained for eac h contract file to ensure necess ary documents are maintained. HUD's Office of Contractin g conducted a review in August 1995 that included recommendations to improve th e procurement process. The Authority has not implemented all of the recommendations because it believes th e Page 73 Office of Inspector General Chapter 11 recommendations have been overcome by the ne w computer system. For example, the Authority has no t established and staffed two Senior Analyst positions. W e were unable to assess the extent to which the new computer system may invalidate the recommendations, since th e Authority only began implementing the purchase orde r module in June 1996. However, because of past problems in the contracting area, it is important for the Authority t o coordinate the resolution of each recommendation wit h HUD. The Blueprint, Lon g-Term Plan, and the Agreement do not contain any goals or strategies relating to the contractin g process. Because of past problems and allegations, w e believe the Authority should include a goal in it s Memorandum of Agreement to develop procedures t o periodically assess the status of its contracting process. A periodic assessment of the Authority's contracting process provides the opportunity to identify and implement actions needed to correct a problem before the problem gets out of control. A periodic assessment also provides HUD an d Authority Management some assurance about the integrity of the system. We recommend HUD coordinates with the Authority to assess the status of the recommendations in HUD's August 1995 review and to ensure HUD agrees with actions or lack of actions taken to correct the problems the recommendations were made to address. We recommend HUD assures the Authority develops procedures to conduct a periodic analysis of its contracting process and initiates actions necessary to improve the process. The Authority's Deputy Executive Director of Finance and Management's Comments Management provided the following comments: • A new policy has been developed which will allo w Authority operational personne l to purchase any item(s) at designated hardware stores subject to establishe d dollar limits. Office of Inspector General Page 74 Chapter 11 • A new policy has been developed which will allo w operational personnel to use the existing hardwar e accounts to purchase any item(s ) as long as dollar limits are not exceeded. • Terms of the open supply and service accounts hav e been distributed to reviewing officials. • All hardware store vendors have been contacted an d told to include retail and discounted prices on al l invoices. Purchasing, Accounts Payable a nd Operations personnel will closely monitor the invoices to ensur e compliance. • Actions will be taken to assess operations of th e Procurement Department by the due date (Septembe r 30, 1997). Estimated completion date: June 30, 1997. • The Authority will try to facilitate a meeting with th e Illinois State HUD of fice to bring closure to the August 1995 review. • Procedures will be established to ensure a periodi c review of the contracting process is conducted . Estimated completion date: August 31, 1996. The Authority developed a policy to address th e Evaluation of Comments recommendation to establish written p rocedures that outline the emergency procurement process. The policy give s development managers the flexibility to use blanke t purchase orders to purchase any item subject to dolla r limits. The policy states that the intent of establishin g blanket purchase orders i s not to circumvent the warehouse or the purchasing process. However, the policy does no t outline the process. We believe written procedure s covering emergency purchases sti ll need to be developed to ensure efficient use of resources and to establish a basis to determine if the procurement process is circumvented. The actions the Authority has completed and is planning i n response to our other recommendations should improve its procurement and contracting functions and help to identify potential problems. Page 75 Office of Inspector General Chapter 11 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 76 Chapter 12 Accounting Systems and Controls Past reviews conducted by HUD, independent public accountants, and the Chicago Housin g Authority's Inspector General showed the Authority did not have an effective accounting system to manage its financial activities. The re views noted that the Authority did not have an adequate system, policies, procedures, or controls for cash management. The Authority's Long-Term Plan contains a strategy to impl ement a fully integrated Management Information System which includes accounting system modules. The Memorandum o f Agreement between HUD and the Authority contains specific strategies and target dates t o improve financial accounting and reporting capabilities. New accounting system. The Authority is taking steps that Observations should enable it to effectively carry out its accounting and financial functions. The Authority has established a ne w chart of accounts. The new accounts track operatin g income and expenses and identify HUD and non-HU D funding sources. The Authority is converting its presen t accounting functions to a new integrated computer system that was developed by Creative Computer Solution s Systems. Additionally, the Authority is pla nning to develop and implement a site-based budgeting strategy. The Authority purchased seven modules that relate to th e Authority's financial operations. Additionally, th e Authority is evaluating the budget preparation and payroll modules to determine if they will fulfill the Authority' s requirements or if the Authority needs to acquire different modules (see Chapter 13 for a discussion of the budge t preparation and payroll modules that should b e implemented by December 31, 1996). As of August 1 , 1996, the Authority has begun using all seven modules and is in the process of fully implementing them into th e integrated system. The modules consist of the following : (1) tenant accounting, (2) purchasing, (3) g eneral ledger, (4) fixed assets, (5) bank reconciliation, (6) inventory control, and (7) accounts payable. The Creative Computer Solutions integrated compute r system is in use at other housing authorities nationwide . We contacted two authorities using the system and th e applicable HUD program office s. The authorities said their systems consisted of the same modules that are bein g implemented or being evaluated for implementation at the Chicago Housing Authority. The authorities and th e Page 77 Office of Inspector General Chapter 12 applicable HUD offices said the i ndividual modules formed a complete accounting system. Both said they wer e satisfied with the operation of the system and the reporting products it generated. New policies and procedures. The Authority has draf t policies and procedures for each incremental accountin g function included in its integrated system wit h the exception of the general ledger. The general ledger does not require policies and procedures. After each particular function i s fully implemented, the Authority plans to review the draft policies and procedures, make necessary adjustments, and then issue the final policies and procedures. To evaluate the draft procedures, we reviewed those for fixed assets , inventory control, tenant accounting, accounts payable and purchasing. The draft procedures appeared to adequatel y cover the necessa ry functions and control areas. However, it is important to issue final procedures that have bee n tailored to each module as soo n as possible after the system is implemented so the system is operated consistently an d can be tested for accuracy. Site-based budgeting strategies. The Memorandum o f Agreement requires the Authority to implement strategie s for a site-based budget. The Authority plans to develo p these strategies after it has selected and implemented a budget module. The target dat e to have a site-based budget is December 31, 1997; therefore, sufficient time should be available to effectively develop the strategies an d implement the site-based budget. We recommend HUD closely follows the Authority's progress in implementing the new accounting system and provides any assistance necessary to ensure the system is fully implemented by December 31, 1996, and that a site-based budget is achieved by December 31, 1997. We recommend HUD assures written policies and procedures are issued as quickly as practical after each accounting function is implemented. Office of Inspector General Page 78 Chapter 12 The Authority's Deputy Executive Director of Finance and Management's Comments Administration said, "I agree with your observations an d recommendations and will be implementing them." Page 79 Office of Inspector General Chapter 12 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 80 Chapter 13 Management Information System Previous consultant and independent public ac countant reports noted the Authority did not have: a computer system that was fully responsive to its needs; and a formal information securit y policy. The draft Memorandum of Agreement between HUD and the Authority, dated June 21, 199 6 contains a goal to improve the technology capacity of the Aut hority and its staff. The Authority's Long-Term Plan includes strategies to implement a fully integrated management informatio n system and to institute a comprehensive computer training program. Integrated management information system. In August Observations 1995, the Authority solicited proposals for an integrate d management information system. The Authority received four proposals for the new system. Creative Compute r Solutions Systems software was selecte d and a contract was executed in February 1996. The Authority's agreemen t called for the purchase of the following nine modules: (1) tenant accounting; (2) purchasing; (3) general ledger; (4 ) fixed assets; (5) bank reconciliation; (6) inventory control; (7) housing eligibility; (8) accounts payable; and (9 ) maintenance work orders. The Authority is also considering purchasing the budge t preparation and payroll modules. However it has som e concerns with these two modules and plans to do furthe r investigation before making the decision. The Authority's Project Manager said the Authority is reviewing these two modules to determine if they will meet the Authority' s needs. He said the previous Authority managemen t purchased a custom software payroll package and th e Creative Computer Solutions payroll module does no t appear to have all of the software capabilities of tha t system. The Authority also has concerns that the budge t package may not have th e capability to allow the Authority to move to a decentralized budgeting syst em. To ensure the integrated management in formation system is implemented by its December 31, 1996 target date, the Authority needs to promptly make a determination of which payroll an d budget modules it will use. The new Creative Computer Solutions Systems softwar e uses two common operating systems; therefore, th e Page 81 Office of Inspector General Chapter 13 Authority should be able to integrate any new module with relative ease. We found the installation of the nine Creative Compute r Systems software modules was proceeding ahead of th e December 31, 1996 sche duled target date. As of August 1, 1996, all of the purchased modules were installed. The Authority's new software package is in use at othe r housing authorities. We contacted two of the authoritie s and they confirmed the so ftware package was effective and reliable. We also contacted the appli cable HUD offices and they said the Creative Computer Solutions softwar e package was a very good product that produced the needed reports and information. Because the impl ementation of the Authority's new software modules were in their infancy, we were unable to evaluate the Authority's use of them . However, the modules appear adequat e and if the Authority properly uses them, it should have an effective dat a processing program. We recommend HUD assures the Authority evaluates and selects the budget and payroll modules immediately, so the modules can be implemented by the December 31, 1996 target date to have a functioning integrated management information system. We recommend HUD assures the Authority establishes controls and procedures to complete the implementation of its integrated management information system by December 31, 1996, and to periodically assess its information needs. Software training. Training was provided on each of the Creative Computer Systems' software modules for th e applicable employees involved with each module. Th e training was conducted by the software manufacturer an d completed in July 1996. The Director of Managemen t Information Systems said additional software training will be an on-going process. The Authority is also in the process of p roviding training on its standardized software. The Authority's standardize d software system includes Windows/Word/Excel/Exchange Office of Inspector General Page 82 Chapter 13 software as well as, numerous adv anced services such as E- Mail communications and access to the Internet . As of June 1996, the Authority had approximately 600 users on-lin e and are adding users d aily, with plans of having potentially over 1,000 users. As of August 1, 1996, the Authority had trained 363 employees or 51 percent of applicable users . The training was conducted by experienced in-hous e instructors. The Project Manager said the standardize d software training is scheduled to be completed b y September 30, 1996. The September 30, 1996 completion date provides the A uthority a buffer to help ensure the new integrated system will be fully operati onal by December 31, 1996. It is important for the Authority to ensure all employee s who use computers receive software training so they ca n effectively use the new system. We recommend HUD assures the Authority establishes controls and procedures to ensure all applicable employees receive software training by December 31, 1996, the day the new integrated system will be fully implemented. Help desk. The Management Informati on System Division established a help desk for all users. The help desk i s contacted by one universal phone number and is currently staffed with one assistant. The Director of Managemen t Information Systems said he plans to add additiona l assistants. As of July 18, 1996, the Authority wa s interviewing candidat es to fill additional assistant positions at the help desk. A help de sk provides information to users quickly so they can more effectively use the system, and it helps eliminate computer down time. Information security policy. The Managemen t Information Systems Division is updating each softwar e module's policies and procedures to include ne w information security policies. Th e Authority has contracted with Creative Computer Solutions Systems to develop and implement a position based security policy. Currently, the Authority is using the security policy for its old compute r system which allows access based on the employees ' department. The new system will limit access based on job Page 83 Office of Inspector General Chapter 13 position and need to know. The policies are scheduled t o be updated by August 31, 1996. Because the revisions of the new policies were in thei r infancy, we were unable t o evaluate them. However, when the new policies are updated with the new securit y measures, they should help prevent unauthorized access to the Authority's system. The Authority has hired Deloitt e and Touche to review the internal controls over its revised policies and procedures. We recommend HUD assures the Authority completes the revisions of its policies and procedures and implements all new security procedures by December 31, 1996. The Authority's Deputy Executive Director of Finance and Management's Comments Administration said, "I agree with your observations an d recommendations and will be implementing them." Office of Inspector General Page 84 Chapter 14 Asset Management The Chicago Housing Authority includes privatization of the management of its: (1) low ren t units; (2) pension fund; and (3) deferred compensation program under its asset managemen t function. In the past, the Authority did not manage i ts asset management function in an effective and efficient manner. Spe cifically, the Authority did not maintain its developments in a decent, safe, and sanitary condition. The Authority's pension fund and the deferred compensatio n program were mismanaged. T he mismanagement resulted in a multi-million dollar diversion of assets from the Authority 's pension fund and deferred compensation programs. The Authority's employees who participated in the defe rred compensation program also had not received benefit statements in over a year. After HUD took over the Authority, HUD issued a Blueprint, da ted June 11, 1995, that contained a goal to replace the Authority's existing administrative structure and create a new structure to effectively manage the A uthority's assets and resources. The Authority's draft Memorandum of Agreement, dated June 21, 1996, contains a goal to explore alternative a nd innovative approaches to the Authority's housing programs such as private management. Blueprint and Memorandum of Agreement. The Observations Blueprint's strategi es are: (1) prepare and release a Request for Proposal for private management of the senior housing developments; (2) prepare and release a Request fo r Proposal for management of the pension fund; and (3 ) outsource the management of the deferred compensatio n program. The Agreement's strategy is to pursu e privatization opportunities for the Authority's publi c housing stock by turning over 15,000 units to privat e management entities. The target date for transferring th e units to private management is December 31, 1996. The Authority is in the process of implementing th e strategies contained in the Blueprint and the Agreement . However, the Authority needs to devote additional attention to the privatization of public housing units, the pensio n fund, and the deferred compensation program. Th e Authority also needs to periodically assess the effectiveness of its actions after they have been fully implemented. We believe if the Authority follows through and full y implements the strategies, the Authority will significantl y improve its asset management. Private management of developments. Although the Blueprint only call ed for the transfer of management of the senior developments to private f irms, the Authority decided Page 85 Office of Inspector General Chapter 14 to also include some family developments. The Authority made this decision in order to include some of its mor e difficult to manage developments in the transfer. On August 7, 1995, the Authority issued a Request fo r Qualifications to identify private management firms tha t possessed the qualifications necessary to manage th e Authority's developments. The Authority received 3 4 responses. The Authority evaluated the responses for their technical competence, scope of services, and minorit y status/opportunities to be offered to disadvantage d individuals. The Authority executed contracts with 15 private firms . The private firms took over t he day-to-day operations of 23 developments effective July 1, 1 996. The 23 developments contain over 8,000 units as follows: Development (*-Previously under private management.) Units Scattered Sites-Southwest* 225 Horner Homes 1,474 Scattered Sites-West* 382 Ogden Courts* 135 Harrison Courts* 126 Maplewood Courts* 131 9141-9177 South Chicago Avenue 298 Hilliard Senior 344 Hillard Family 346 Scattered Sites-Northwest* 339 Lathrop Senior* 92 Scattered Sites-North Central* 417 Madden Park 485 1611 South Racine 212 Rockwell Gardens* 1,126 150 South Campbell 129 Archer Courts* 147 Loomis Courts* 126 Judge Green Apartments* 154 Lake Parc Place* 284 Scattered Sites-Northeast 381 Scattered Sites-Southeast 425 Prairie Courts* 324 Office of Inspector General Page 86 Chapter 14 Sixteen of the 23 developments consisting of approximately 4,500 units were previously under private management . The Authority made significant changes in its new private management contracts to improve the private firms ' accountability for result s. For example, the contracts were standardized, budget revisions now require approval, th e firms must use the Authority's new computer system, an d performance standards have been clarified. Under the new contracts, private firms operate th e developments using operating budgets. The firms ar e initially advanced tw o months operating expenses and then are moved to a monthly reimbursement. The operatin g budgets do not include funds for major renovations. Major renovations are planned a nd budgeted for by the Authority. For all eleven of the contracts we reviewed, th e management fees remained essentially the same or wer e reduced from the previous fees charged. The fee structure was changed to provide an emphasis on occupying units. We were unable to evaluate the effectiveness of the ne w contracts, since they have not been in force a sufficien t length of time. However, our analysis of the contract' s terms indicated the changes that em phasize occupying units and improving accountability should result in bette r customer service. Although the contracts have bee n improved, proper monitoring of the private managemen t firms is essential to ensure performance standards are met. The Deputy Executive Director of Operations said th e Authority plans to have another 3,500 units under contract by September 30, 1996 and the remaining 3 ,500 units under contract by December 31, 1996. We recommend HUD assures the Authority monitors the private management firms to ensure the developments are maintained in an adequate manner and according to the management contracts, and that the Authority takes appropriate action if firms do not properly manage the developments. We recommend HUD closely watches the Authority's progress to privatize 15,000 units by December 31, 1996 Page 87 Office of Inspector General Chapter 14 to ensure privatization contracts are providing acceptable housing at a reasonable cost. Monitoring private management contracts. The Authority assigned monitoring responsibility of the private management contracts to its Private Managemen t Administration and its Department of Finance for Publi c Housing/Private Management. The Private Management Administration's responsibilities include physical inspections of the developments' grounds and units, reviewing tenant files for accuracy of renta l calculations, and processing monthly stat us reports from the private firms. The Department of Finance for Publi c Housing/Private Management's responsibilities includ e reviewing and approving payment requests, budge t revisions, and performing audits of the private management contractors. The Private Management Administration and th e Department of Finance for Public Housing/Privat e Management have not established a coordination process to address issues that arise during their monitoring. Effective communication and coordination is important to assur e HUD and the Authority that resou rces are only expended to achieve stated objectives of im proving living conditions for the tenants. We recommend HUD assures the Authority establishes coordination procedures between Private Management Administration and Department of Finance for Public Housing/Private Management for monitoring the private firms. Private management of the pension fund. The Authority issued a Request for Proposa l on August 14, 1995 to obtain an investment consultant for the pension fund. A contract was executed with Bec ker, Burke Associates on October 1, 1995 to identify investment management firms to manage the Authority's pension fund. The investment consultant identified four firms for th e Plan's Board of Trustees consideration. The Board o f Trustees selected t wo firms based upon interviews with the Office of Inspector General Page 88 Chapter 14 firms and reviews of their investment strategies. Contracts were executed with The Burridge Group and The Chicago Trust Company on December 21, 1995. The Plan's Board of Trustees will be responsible for monitoring the pension fund contracts. The investment consultant and the tw o management firms were providing the services as required by the contracts. The contractors also provided th e necessary reports to allow the Trustees to monitor the fund. Contracting out has impro ved the operations of the pension fund. However, the Board of Trustees issued Requests fo r Proposals on December 22, 1995 to obtain legal , accounting, auditing, and actuarial services for the pension fund. While the Board of Trustees notified the selecte d firms on January 25, 1996 of the contract awards, th e Authority has no t executed written contracts with the firms as of July 11, 1996. The Deputy Executive Director fo r Finance and Administration said contracts have not bee n executed because the Authority was focusing its effort s towards finding a new Plan Administrator and assurin g pension benefit payments were being issued timely. Th e former Plan Administrator left the Authority abruptly o n April 26, 1996. A new Plan Administrator was hired o n June 19, 1996. Written contracts ar e essential to outline the necessary services and to protect the Authority's interest. We recommend HUD assures the Authority executes contracts with the legal and actuarial firms selected for award. (Contracts for the accounting and auditing services were executed on August 8, 1996 after we had completed our review of this area). We recommend HUD assures the Authority properly oversees the contracts awarded for the pension fund and takes appropriate action if the contractors do not effectively perform the required services. Private management of deferred compensation program. The Authority issued a Request for Proposal on May 30, 1995 to outsource the def erred compensation plan. On November 1, 1995, a contract was executed with th e Public Employees Benefit Service Corporation t o administer the plan. The firm's responsibilities includ e Page 89 Office of Inspector General Chapter 14 group meetings with the Authority's employees, enrollin g participants in the plan, and issuing quar terly benefit reports to the plan participants. The plan's administrator wa s providing the services and reports as required by th e contract. This has improved the operations of the deferred compensation program. The Authority's Manager of Financial Report ing and Tenant Accounting was responsible for monitoring the deferre d compensation contract; however, the Manager said, with his other duties, he did not have adequate time to monitor the contract. The Manager said he was assigned oversigh t responsibility in June 1994 on a temporary basis, and th e Authority has not reassigned the monitoring responsibility to another staff member. When we brought this to th e Authority's attention, the monitoring of the deferre d compensation contract was reassigned to the Authority' s Human Resources Department. Effec tive monitoring of the contract is important to ensure past problems with th e program do not reoccur. We recommend HUD assures the Authority establishes controls to ensure the deferred compensation contract is adequately monitored and appropriate actions are taken if the firm under contract is not properly managing the deferred compensation program. The Authority's Deputy Executive Director of Finance and Management's Comments Administration said, "I agree with your observations an d recommendations and will be implementing them." Regarding private management of developments, th e Authority's Deputy Executive Director of Operations said, "The Chicago Housing Authority concurs with th e observations and associated rec ommendations as stated and will incorporate same in our overall planning efforts." Office of Inspector General Page 90 Chapter 15 Risk Management The Chicago Housing Authority's Risk Management Departm ent is responsible for administering the workman's compensation program and prote cting the Authority against liability and property claims. The goal of risk management is to reduce insurance claims and costs. A prior repor t issued by the Authority's In spector General found the Authority's in-house administration of the workman's compensation program was not effectively, efficiently, or economically managed . The program was administered without proper planning, management, staffing, and writte n policies and procedures. The Authority also lacked a safety program and did not conduct a n adequate analysis of its insurance coverage. The HUD Blueprint, dated June 11, 1995, c ontained a goal to replace the existing administrative structure and create a new structure to manage the Authority's risk. To accomplish this goal , HUD established a strategy to investigate the procurement of a third party administrator for the workman's compensation p rogram. The Authority's Long-Term Plan, dated February 15, 1996, contained strategies to meet the goal of devoting increased emphasis to risk management. The Plan set a target date of March 30, 1996 to hire a new program director, and May 30, 1996 t o develop a safety program. The Authority's draft Memorandum of Agreement, dated June 21 , 1996, did not contain any goals or strategies relating to risk management. Private management of the workman's compensation Observations program. The Authority issued a Request for Proposal on September 29, 1995 to obtain a third party administrator for the workman's compensation program. A contract wa s executed with Coresource, Inc. on March 27, 1996 . Because of the contract, the Authority is reducing it s workman's compensation staff from six to one. The on e employee is being retained to assist the Director of Ris k Management in monitoring the contract. The contract contains specific perform ance standards which the firm must abide by when administering the contract . The performance standards establish a basis for th e Authority to effectively monitor the firm and hold the firm accountable for its performance. Because sufficient tim e has not elapsed since the w orkman's compensation contract was awarded and the claims were transferred, we wer e unable to assess the effectiveness of th e contract. However, we determined the Authority is receiving the monthl y reports from the firm to monitor the program and is usin g them to develop ways to reduce claims. For example, the Authority initiated a training course to instruct employee s on the proper way to lift heavy materials. Page 91 Office of Inspector General Chapter 15 We recommend HUD assures the Authority aggressively monitors the workman's compensation contract and takes appropriate actions if the firm does not properly manage the program. We recommend HUD assures the Authority periodically conducts an analysis to determine if it is more cost effective to contract out the administration of the workman's compensation program versus theAuthority administering the program in-house. Risk management program. The Authority established a target date of March 30, 1996 to hire a Director of Ris k Management to replace the former Director who diverte d funds. On November 20, 1995, the Autho rity hired the new Director. The new Director has an exte nsive background as a risk manager and risk consultant. Safety Program. The Authority established a target dat e of May 30, 1996 to develop a safety program. Th e Authority developed a safety plan on December 1, 199 5 and is in the process of implementing the program. Th e program consists of training for employees and resident s and procedures to identify hazards in order to reduc e property and casualty claims against the Authority. The Authority initiated the emp loyee training portion of the safety plan. For example, it has conducted employe e assistance training which deals w ith alcohol and drug abuse problems. The Authority, however has not init iated resident training, although its target date for implementing th e training was March 1996. The resident training wa s delayed because video equipment needed for developin g training materials was not received on time. The Authority received the video equipment in May 1996 and expects to initiate resident training by September 30, 1996. Training residents on safety procedures helps ensure residents wil l take the proper actions in emergency situations and thu s reduce casualty and property losses. We recommend HUD assures the Authority initiates safety training for its residents by September 30, 1996. Office of Inspector General Page 92 Chapter 15 Safety inspections. In June 1996, the Authority hired a Safety Inspector to coordinate and train developmen t managers on how to conduct inspections to identify an d eliminate hazardous conditions at developments. Fo r example, the Authority determined that a high number of its claims came from pot holes, fence posts left after fence s were removed, and defective playground equipment. The Safety Inspector personally reviewed eac h developments' parking areas and roads for pot holes an d reported the problems to the City of Chicago who i s responsible for corrective action. The Authorit y periodically follows up with the City to determine i f corrective action has been taken. Development managers were responsibl e for inspecting and ensuring corrective action was taken regarding the fenc e post problem and defective playground equipment. Th e Risk Coordinator who oversees the safety program had the results of the Safety Inspector's review of the pot holes ; however, he did not have any information for th e inspections accomplished by the development managers. It is important for the Authority to monitor the status o f inspections at the developments, so it can ensure th e hazardous conditions have been eliminated. We recommend HUD assures the Authority develops procedures to track hazardous conditions until the conditions are eliminated. Purchase of Insurance. Because of the emphasis on risk management, the Authority now purchases insurance more intelligently and has reduced its insurance premiums. For example, in March 1996, the Authority did not renew it s public official liability policy since the Authority was also covered under another policy. As a result, the Authorit y was able to save $272,782. For the first time, the Authority has developed a list of al l its properties and t heir values. The list is a valuable source of information for calculating the correct coverage needed for its insurance programs. Page 93 Office of Inspector General Chapter 15 We believe the actions the Authority has t aken will improve its risk management program; however, the Authority needs to periodically evaluate the results of its actions and tailor the program to meet new conditions. Because of pas t problems, the Authority should develop procedures t o periodically assess its risk management program. A periodic assessment of the Authority's risk managemen t program provides the opportunity to identif y and implement actions needed to correct a problem be fore the problem gets out of control. We recommend HUD assures the Authority develops procedures to periodically assess its risk management program and makes changes to address new conditions. The Authority's Deputy Executive Director of Finance and Management's Comments Administration said, "I agree with your observations an d recommendations and will be implementing them." Office of Inspector General Page 94 Chapter 16 Personnel A past consultant review of the Chicago Housing Authority showed the Authority's personne l function needed improvement. The consultant found the Authority's job descriptions wer e inaccurate and not useful in hiring personnel or in evaluating performance, employees' salaries bore little relevance to the market, and performance evaluations were not effective. Additionally, a basic skills assessment the Authorit y gave to its maintenance employees raised concerns about the qualifications of the housing management staff and the Authority's recruiting process. To correct the problems, the Authorit y included strategies in its Long-Term Plan and goals in its June 21, 1996 draft Memorandum of Agreement with HUD. The documents have simila r objectives. The Memorandum of Agreement contains goals to assess and develop staff skil l levels to improve housing management capacity, staff performan ce, and productivity. The Long- Term Plan has three st rategies to achieve a committed, competent, and professional work force. The strategies are: (1) provide pro-active training and cross-training for staff and professiona l development skills; (2) implement an adequate compensation and performance system; and (3) aggressively recruit skilled workers. Assessment of management staff skill levels. The Observations Authority reviewed the skills and capabilities of its sit e managers, maintenance employees, and recruiters. All site managers' backgrounds wer e reviewed to determine if they met HUD's cer tification requirements. Thirty-seven managers did not. Consequently, during the past nin e months, most of the managers were given certificatio n training. As of July 15, 1996, only 11 managers remai n uncertified. The Auth ority mandated that the remaining 11 managers will take certification trai ning in November 1996. In connection with the new computer system, maintenance employees were giv en a basic skills assessment. The basic skills assessment required supervisors and workers to read, write, and perform math functions at an eighth and sixt h grade level, respectively. Only 54 percent of the supervisors and 48 percent of the workers passed. The Authority also analyzed all 59 maintenance positio n descriptions and found only 22 of the 59 description s specifically stated that the employee must be able to read, write, and comprehend work orders. The Human Resources Department is in the process of revisin g the job descriptions to fill this gap. The Human Resources Director said th e revisions will be comple ted by August 1996. Additionally, Page 95 Office of Inspector General Chapter 16 the Authority has compiled a lis ting of various literacy sites around the greater Chicago area and is strongl y encouraging applicable maintenance supervisors and workers to atten d classes to improve their skills. The Authority is currentl y reviewing its options through the unions and its Lega l Department to determine what actions it can take i f employees do not improve their skills. The Authority determined th at it needs to have experienced recruiters to identify and recruit skilled workers. As a result, the skills and capabilities of the Human Resource s staff were assessed. The Authority created new position s and made staffing changes in its Human Resources staff . Job qualifications that contain skill levels for each of th e new Human Resources positions were created. Th e Authority is in the process of creating an annual recruitment strategy. Recruiting sources are being identified an d methods to recruit are being developed to accomplish th e strategy. The Authority-wide revision of job descriptions, that contain expected skill requirements, will assist th e recruiters in identifying qualified candidates for vacancies. The Authority informally assessed its staff's skill level i n other areas. Management has made staffing changes an d replaced personnel as they deemed necessary. Fo r example, in Finance and Administration, five out of eigh t directors were hired within the last six months and there has been a turnover of approximately 50 percent of th e Management Information Systems' staff. However, wit h the exception of the site managers, ma intenance employees, and recruiters, the Authority has not performed a forma l assessment of its staff. It is important for the Authority to have an assessment that includes all its staff so it ha s assurance employees are qualified for the positions they are filling, and can develop training programs where needed. We recommend HUD assures each of the Authority's managers have been certified by the March 31, 1997 Memorandum of Agreement target date for assessing and developing staff skill levels. We recommend that HUD assures the Authority develops and implements strategies to address (1) the Office of Inspector General Page 96 Chapter 16 skill level of all its staff, and (2) the issue of staff who do not meet minimum required skill levels. We recommend HUD assures the Authority develops an effective recruiting strategy that properly assesses the qualifications of potential employees. For the first time, the Authority has a lso established a group of core courses to train housing management personnel. A core course is a required arrangement of fundamenta l curriculum that combines basic topics to provid e participants with a common background on variou s subjects. The Authority developed the curriculum an d materials for the courses. The Authority implemented a n employee orientation class to familiarize new staff with the Authority's policies and procedures. The Authority's 1996 staff training catalog contains 37 courses. For example, the Authority offers a course entitled "Progressive Discipline" that provides managers with guidelines to addres s disciplinary problems. Twenty-two of the courses will b e taught by instructors from the Human Resource s Department, two by outside contractors, and the remaining 13 are to be given by Housing Management staff. Because of recent reductions in staff levels, the Housin g Management trainers have not been determined. The Authority also plans to use local real estate trainin g organizations to provide specialized training that th e Authority's staff is unqualified to give. For example, th e Authority plans to have the National Center for Housin g Management give certification training to its eleve n managers in November. If the Authority follows through with i ts planned actions, its staff should have the means to develop necessary housing management skills. We recommend HUD assures the Authority appoints qualified instructors and implements the courses by the September 30, 1996 target date established in the Memorandum of Agreement. System to track the training. Presently, the Authorit y keeps track of its employees training with sign-in sheets . Page 97 Office of Inspector General Chapter 16 The employees receive certificates for satisfactor y completion of a training course. However, variou s departments, in addition to Human Resources, give staf f training. The Legal Department provides evictions training, the Management Information Systems De partment provides computer training, and the Purchasing and Contracts' staff provides procurement training. There is no consolidate d record of an individual's training. Sign-in sheets do not provide a convenient record o f training that can be used by managers for plannin g purposes. There w as not a specific order or location for all sign-in sheets. For example, the Authority has n o consolidated record of which managers receive d performance management training. The information wa s only available from staff m emory or research of all training sign-in sheets. An accurat e method to document training is important for budgeting purposes, to prevent unnecessar y duplication of training, and to ensure all personnel have the necessary skills. The Deputy Executive Director of Finance an d Administration said that the Authority plans to implement a computer database to track employee training. We recommend HUD assures the Authority establishes and implements procedures to consolidate the tracking of training received by its employees. Staff performance, productivity and commitment. In 1994, the Authori ty commissioned a consultant to study its compensation program, job descriptions, and performance program. The consultant found that the Authority's pa y rates were not relevant to the overall market, jo b descriptions were inaccurate and were not useful in hiring or evaluating performance, and job performance was no t effectively tied to pay. While the compensation study was completed in 1995, the Authority's previous administration did not implement it s recommendations due to bu dgeting difficulties. On June 1, 1996, the Authority's new management team began t o implement the study's recommendations. Office of Inspector General Page 98 Chapter 16 The consultant's recommendations regarding pay rates are in the process of being implemented for the Authority' s non-union positions. This action is planned to b e completed by December 31, 1996. For the unio n employees, the consultant's recommended rates hav e received the union's approval and will go into effect o n January 1, 1997. The Authority has revised most of the job descriptions . However, about 60 percent of the job descriptions nee d additional minor revisions due to recent reorganizations in various departments. The Authority's pay for performa nce program requires each of its managers to meet with their staff to review the jo b performance standards and establish expectation levels for each employee's goals and objectives. A merit salar y increase is earned by an employee as a result of jo b performance. Interim performance reviews are currentl y being conducted by the A uthority and should be completed by July 31, 1996. The final performance reviews ar e scheduled for the end of the year. We believe employees' perform ance will improve when the Authority's compensation system and its pay fo r performance syste m are fully implemented. The Authority is on schedule to have the systems fully implemented by its Long-Term Plan target date of March 31, 1997. We recommend that HUD monitors the Authority ot assure it completes the implementation of the compensation system and job descriptions by March 31, 1997. The Authority's Deputy Executive Director of Finance and Management's Comments Administration said, "I agree with your observations an d recommendations and will be implementing them." Page 99 Office of Inspector General Chapter 16 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 100 Chapter 17 Resident Program Delivery Systems In the past, the Chicago Housing Authority did not conduct an assessment to determine th e services required by its r esidents. According to HUD's 1995 Recovery Team report, because of the Authority's size and the limited economic and human resources, the service needs of th e residents have out-paced the capacity of the Authority's staff. HUD's Blueprint, dated June 11, 1995, contained strategies to meet the go al of increasing resident participation in the decisions that affect their lives. The Authority's Long-Term Plan, date d February 15, 1996, contained strategies to meet the goal of enhancing the resident progra m delivery systems. The June 21, 1996 draft Memorandum of Agreement did not contain an y strategies or goals related to resident delivery systems. Blueprint and Long-Term Plan. The Blueprint's majo r Observations strategies are: (1) establish a system-wide resident planning process and give residents unprecedented involvement i n planning the redevelopment of their communities; and (2) follow through with the State of Illino is and The Woodlawn Organization to open a transition facility for Authorit y families in crisis. The Plan's strategies are: (1) determine and identify issues and needs involving existing and potential services an d delegate agencies; (2) ev aluate the effectiveness of existing and potential service delivery systems; (3) conduct a cost/benefit analysis of existing and potential servic e delivery systems; (4) select from existing and potentia l services and delegate agencies that best meet residents ' needs not currently addressed; (5) monitor the ne w programs and services; and (6) identify future residen t needs. The Authority has met or is on target to meet the Blueprint's and Plan's strategies except for: (1) determining an d identifying issues and needs involving existing an d potential services and del egate agencies; and (2) evaluating the effectiveness of potential service delivery systems. Resident Involvement in Planning Process. The Authority moved t o provide residents more involvement in the planning process of redeveloping their communities . On December 18, 1995, the Authority issued a Request for Qualifications to i dentify urban planners that possessed the qualifications necessary to work with the residents t o Page 101 Office of Inspector General Chapter 17 produce a long-range strategic plan for physical and social service needs in their communities. The plans are t o include: (1) an assessment of the physical design of eac h community; (2) an assessment of available commercia l businesses, recreation facilities, and day care; and (3) a n assessment of soci al service needs and programs necessary to meet those needs. The Authority received eig ht responses and evaluated them based upon the following criteria: (1) specialize d knowledge, experience, and technical competence in th e type of work required; (2) capability to provide the required services on a timely basis; (3) past performance based upon references of former clients serviced; a nd (4) overall quality of the response submitted. All eight firms met th e evaluation criteria. The Authority's Local Advisor y Councils are responsible for selecting an urban planner . The Local Advisory Councils for Henry Horner, ABL A Homes, and Rockwell Gardens selected an urban planne r and the Authority executed the contracts effective May 31, 1996. The contracts required the planner to complete th e planning services by July 31, 1996. The Authorit y extended the Henry Horner and ABLA Homes contracts to September 30, 1996 and the Rockwell Gardens contract to September 30, 1997. However, the extensions were no t granted prior to the expiration of the original contract an d were not in writing as required by section 3.03 of th e contracts. The Local Advisor y Councils for Dearborn Homes, Robert Taylor B, Wentworth Gardens, Hilliard Homes, Lathro p Homes, Washington Park, and Trumball Park have als o selected urban planners to assist in the redevelopment o f their communities. The Authority plans to have contract s executed with the urban planners by August 31, 1996. The Deputy Executive Director for Community Relations an d Involvement said the Authority anticipates having th e remaining eight Local Advisory Councils select an urba n planner by December 31, 1996. The Authority needs t o ensure the remaining Councils select an urban planner a s expeditiously as possible so the redevelopment of thei r communities can progress in a timely manner. Office of Inspector General Page 102 Chapter 17 We recommend HUD assures the Authority follows the requirements of its contracts and ensures all contract extensions are made before the original contract expires and are in writing. We recommend HUD assures the Authority: (1) executed contracts with the urban planners for Dearborn Homes, Robert Taylor B, Wentworth Gardens, Hilliard Homes, Lathrop Homes, Washington Park, and Trumball Park; and (2) ensures the remaining eight Local Advisory Councils select an urban planner as expeditiously as possible but no later than December 31, 1996. Development Initiatives Division. The Authorit y established a Development Initiatives Division in Augus t 1996 to assist its residents in developing, implementing , and monitoring various developmental initiative programs. The Division will conduct related training on strategi c planning, homeownership, and Hope VI communit y services programming related to initiatives for th e Authority's residents. The Divi sion will also be responsible for other special projects to im prove the living environment of residents. The Development Initia tives Division staff are required to establish policies, procedures, and programs in coordination with the Authority's executive staff. Th e policies and procedures will dire ct the Division's operations in the Resident Development Programs. The Dir ector of the Development Initiatives Division said the Authority wil l have written policies and procedures implemented b y September 30, 1996. The policies and procedures ar e essential to outline the Authority's commitment to th e servicing of its residents. Based upon the actions taken by the Authority to obtain urban planners and establish th e Development Initiatives Division, resident involvement in decisions that affect their lives has increased; however, the Authority needs to continue to find additional ways t o increase resident involvement. We recommend HUD assures the Authority established policies and procedures for its Development Initiatives Division by September 30, 1996. Page 103 Office of Inspector General Chapter 17 Transition Facility. The Authority followed through with the State of Illinois and The Woodlawn Organization i n establishing a transition facility for families in crisis. Th e facility is the Chicago Holistic Interim Livin g Development. It is operated and partially funded by The Woodlaw n Organization. The remaining funds for the facility ar e provided by the Illinois Department of Children and Family Services, the African America n Leadership Partnership, the Authority, the Museum of Science and Industry, an d Maryville, which is a housing component of the Catholi c Archdiocese. The facility offers counseling, a 24 hou r crisis line, housing assistance, infant and toddler day care, substance abuse and domestic violence intervention, family field trips, extended community transportation, emergency family shelter, and job skills and development placement in order to address the needs of the whole family. As of July 8, 1996, the facility had 300 families registered in it s program. The facility initia lly opened on June 21, 1995 in temporary mobile units that offered services on a limited basis. O n December 1, 1995, the facility moved into two renovate d buildings at the Ida B. Wells development that had bee n donated by the Authority. The facility was established i n response to the 17 children found in June 1994 living i n deplorable conditions in t he City of Chicago and the deaths of two children at the Authority's Ida B. Wells and Cabrini Green developments. The Deputy Executive Director o f Community Relations and Involvement said the Authority plans to establish a similar facility at the ABLA Home s development when funding is secured from the State o f Illinois. We recommend HUD assures the Authority establishes a transition facility at the ABLA Homes development when the necessary funding is obtained and explores establishing additional transition facilities at other developments based upon the needs of the residents. Existing/Current Services and Delegate Agencies. On November 15, 1995, the Authority issued a Request fo r Proposal to obtain technical assistance for its curren t resident initiatives programs. The Authority received 1 8 responses and evaluated them based upon technica l Office of Inspector General Page 104 Chapter 17 competence, qualifications of key personnel, the proposed fee to be charged, and minority business enterprise/women business enterprise participation. The Authority execute d a contract with E ducational Training and Enterprise Center effective August 26, 1996 with a completion date o f December 26, 1996. The Authority' s Community Relations and Involvement Division is responsible for monitoring the contract. The contract requ ires the Center to: (1) determine and identify issues and needs involving existing service s and delegate agencies; (2) evaluate the effectiveness o f existing service delivery systems ; (3) conduct a cost/benefit analysis of service del ivery systems; and (4) identify future needs. The Authority needs to monitor the contract t o ensure it and its residents receive the services as required. Due to the effective date of the contract, the Authority will not meet its Long-Term Plan's September 30, 199 6 completion date f or determining and identifying issues and needs involving the existing/current services and delegat e agencies. The Authority has revised the Plan's completion date to December 31, 1996. The strategies to: (1) evaluate the effectiveness of existing service delivery systems; (2 ) conduct a cost/bene fit analysis of service delivery systems; and (3) identify future needs, have completion dates o f March 31, 1997, June 30, 1997 and December 30, 200 0 respectively. Since the completion date of the Educational Training and Enterprise Center contract is December 26 , 1996, the Authority should co mplete the actions well ahead of the target dates. The Deputy Executive Director for Community Relation s and Involvement said once the Authority receives the report from the Educational Training and Enterprise Center, th e Authority will be able to select from the existing service s and delegate agencies that best meet the residents' needs by January 31, 1997. The actions taken by the Authorit y should increase its resident delivery systems. We recommend HUD assures the Authority monitors the contract with the Educational Training and Enterprise Center to ensure it receives the required services by December 26, 1996. Page 105 Office of Inspector General Chapter 17 We recommend HUD assures the Authority takes appropriate action by January 31, 1997 based upon the Educational Training and Enterprise Center's report. The Authority should only select, for continued use, those existing services and delegate agencies that are shown to best meet its residents' needs. Potential/Future Services and Delegate Agencies. After the Educational Training and Enterprise Center ha s completed its review of the existing/current services an d delegate agencies, the Authority will identif y potential/future s ervices and delegate agencies. The Long- Term Plan's completion dates for identifyin g potential/future services and agencies and evaluating their delivery systems are September 30, 1996 a nd December 31, 1996, respectively. The Deputy Executive Director fo r Community Relations and Involvement said the Authority will not meet the Plan's completion dates for these tw o strategies. He said the Authority let these dates slip t o concentrate on resident employment initiatives. Th e Authority revised the completion date s to January 31, 1997. Once the Authority has identified the potential/futur e services and delegate agencies, it plans to conduct a cost/benefit analysis of their delivery systems. The Long- Term Plan's completion date for conducting the analysis is June 30, 1997. The Authority should meet the target date for conducting the cost/benefit analysis of the potentia l services and delegate agencies if it follows through an d completes its other strategies related to exi sting services and agencies. After the analysis is completed, the Authorit y will select the potential services and delegate agencies that best meet the resident s' needs not currently addressed. The potential services and agencies selected should also b e completed by the Plan's target date of September 30, 1997. The Director of Resident Programs is responsible fo r monitoring the potential servic es and delegate agencies that are selected. Based upon the proposed actions, the needs of the residents not addressed should be corrected. We recommend HUD assures the Authority performs the following steps related to potential/future services and delegate agencies: (1) identifies and evaluates their delivery systems by January 31, 1997; (2) conductsa Office of Inspector General Page 106 Chapter 17 cost/benefit analysis of their service delivery systems by June 30, 1997; (3) selects those that best meet the residents' needs not currently addressed by September 30, 1997; and (4) monitors services and delegate agencies to ensure the residents' needs are being addressed. The Authority's Deputy Executive Director of Community Management's Comments relations and Involvement said, " I am in agreement wit h your observations, howe ver, I offer the following comment concerning your recommendation that the Authorit y continue to establish a transition facility at the ABL A Homes development. We recommend that HUD assures the Authority establishes a transition facility at the ABLA Homes dev elopment when, and if, the necessary funding is obtained from the State of Illinois and explore establishing additional transitio n facilities at other developments based upon the needs of the residents. Our recommendat ion regarding a transitional facility at the Evaluation of Comments ABLA Homes development does not include the word s "and if". We believe our wording establishes a greate r commitment on the part of the Authority to achieve th e objective of the recommendation. Page 107 Office of Inspector General Chapter 17 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 108 Chapter 18 Economic Development Opportunities for Residents In the past, the Chicago Housi ng Authority lacked a program to provide economic development assistance to its residents. The Authority has 11 of the 15 poorest census tracts in the Unite d Stated within its developments. A consultant report issued in October 1994 said the Authority had a resident unemployment rate of 90 p ercent while 65 percent of its residents wanted to work and were available for employment. The Authority reestablished the Economic Developmen t Division in December 1995 to offer residents opportu nities to form small businesses and receive employment training and placement. The Division had been previously eliminated in January 1995. The Authority's Long-Term Plan, dated February 15, 1996, contained strategies to meet the goal of improving economic development opportunities for its residents in and around th e developments. The Authority's draft Memorandum of Agreement, dated June 21, 1996 , contained strategies to meet two goals. The Agreement's goals are to: (1) broaden economi c development opportu nities for residents which will decrease the percent of rents uncollected by improving residents' socioeconomic well-being and quality of life; and (2) expand educational, economic, and recreational opportunities for residents. The HUD B lueprint, dated June 11, 1995, did not contain any strategies or goals related to resident economic development. Long-Term Plan and Memorandumof Agreement. The Observations Plan and the Agreement both contain the followin g strategies: (1) develop joint venture agreements wit h resident owned companies and local private secto r businesses; and (2) contract with resident joint ventur e groups to fulfill the Authority's needs for contracte d services labor. The Agreement contains the followin g additional strategies: (1) develop and implement a Section 3 policy statement and guidelines; (2) develop partnership agreements with government, non-profit, and private sector agencies to support resident training and employmen t opportunities; and (3) e valuate the Authority's performance in meeting residents' needs . The Authority has met or is on target to meet all of the Plan's and Agreement's strategie s with the exception of evaluating performance in meetin g residents' needs. Joint Venture Agreements. The Authority ha s encouraged resid ents to form small businesses with private sector entities by conducting tenant meetings and trainin g sessions. The busines ses will provide a variety of services, such as janitorial and unit rehabilitation, at th e Page 109 Office of Inspector General Chapter 18 developments. Since the agreements use residents t o provide the services, they free up the Authority's staff t o complete basic maintenance repairs. A joint ventur e agreement is a contract between the residents and a private sector entity to join resources to provide goods an d services. The agreement details the duties an d responsibilities of each party. The target date in th e Authority's Memorandum of Agr eement was June 30, 1996 to develop joint venture agreements with resident owne d companies and local private sector businesses. Th e Authority met the target date. As of July 31, 1996, ther e were 19 joint venture agreements between residen t businesses and private and non-profit businesses. Th e Authority has projected that the 19 joint venture agreements will create over 500 resident jobs. We recommend HUD assures the Authority continues to emphasize the development ofjoint venture agreements between the resident owned companies and private sector businesses. Joint Venture Contracts. Along with developing join t venture agreements, the Authority established a goal in its Long-Term Plan to execute 25 contracts per year with th e resident owned companies. As of July 31, 1996, th e Authority had executed nine contracts totalling ove r $4,000,000. The cost of the contracts are consistent wit h what the Authority incurred in previous contracts, or would incur if it employed individuals to perform the services . The Authority also has five contracts pending executio n with resident owned businesses. The five contracts should be executed by August 31, 1996. Further, t he Authority has 10 more contracts pending execution by t he end of the year. As a result, the Authority is on track to meet its goal in the Long-Term Plan. We recommend HUD assures the Authority works ot expeditiously complete its pending contracts and continues to explore other contracts with the resident owned companies in order to reach the yearly goal of 25 contracts. Section 3 Policy.The Authority met the Memorandum o f Agreement target date of April 1996 to develop a Section 3 Office of Inspector General Page 110 Chapter 18 policy statement. The policy was i mplemented on May 1, 1996. The policy requires resident hiring to be used on all of the Authority's construction and service contracts of $100,000 or more that contain a labor component. As of July 31, 1996, the Authority had executed 1 9 contracts containing the Section 3 requirement. Th e contracts require over $400,000 to be spent on residen t employment and training. The Authority's Contrac t Compliance Section is responsible for monitoring th e contractors to ensure they meet the Section 3 requirement. Contractors that fail to comply with the Authority's Section 3 policy are supposed to have their payments reduced b y the amount they are required to spend on Section 3 employment and training. As of July 31, 1996 al l contractors have complied with the Section 3 employment and training requirements. The payments retained from contractors not meeting th e Section 3 requirement will be placed in the Authority' s Resident Employment Development Initiatives progra m which develops resident employment opportunities an d training initiatives. Based upon the implementation of the Authority's Section 3 policy, the residents should benefi t from increased employment opportunities. However, th e Authority needs to monitor the contractors to ensure th e residents are receiving the intended benefits. We recommend HUD assures the Authority monitors the construction and service contractors to ensure: (1) residents are receiving the employment and training opportunities as required; or (2) the appropriate amounts are withheld from contractors for failing o t meet the Section 3 requirement. Partnership Agreements. The Authority has develope d partnership agreements with various government, non - profit, and private sector agencies to support its residen t training and employme nt programs. The agreements detail the various employment and training programs targete d towards the Authority's residents. Some of the agencie s are: (1) the Mayor of the City of Chicago's Office o f Employment and Training; (2) the State of Illinois ' Department of Public Aid; (3) the Grand Boulevar d Page 111 Office of Inspector General Chapter 18 Federation; (4) the City of Chicago Empowerment Zone ; (5) the Chicago Public Schools; (6) the City of Chicago' s Colleges; (7) United Parcel Service; and (8) the Unite d States Postal Service. For example, the partnership with the Mayor's Office o f Employment and Training will increase employmen t opportunities for residents ages 16 to 24 through a $ 3 million grant from the U.S. Department of Labor. Th e Authority will use the grant to open a Resid ent Employment Development Initiative's office at the Ida B. Well s development. The partnership with the Illinois' Department of Public Aid provides the Authority with labor resources. Federal mandates require an increasing number of publi c aid recipients to work in order to recei ve their benefits. The United Parcel Service and United States Posta l Service have each committed to hiring and training 50 and 100 of th e Authority's residents, respectively. We contacted three of the agencies that the Authority has partnership agreements with. The three agencies were very pleased with th e cooperation and success they have had with the Authority. The Authority needs to c ontinue to seek additional partners to improve the tenants economic status. We recommend HUD assures the Authority continues to identify government, non-profit, and private sector agencies to form partnerships that will support the Authority's resident training and employment programs. Evaluating Performance. The Memorandum o f Agreement target date to evaluate the Authority' s performance in meeting its residents' needs is March 31 , 1997. HUD assumed responsibility for accomplishing this strategy in June 1995 after the tak eover and contracted with Abt Associates for a resident survey. However, HUD has experienced a delay in obtaining approval from the Office of Management and Budget regarding the evaluation form. HUD's Program Design Coordinator expects to have th e survey initiated in September 1996 and completed i n November 1996. As part of the Memorandum o f Agreement strategy a second survey will be conducted a year later to evaluate if the Authority's performanc e improved. HUD plans to complete the second survey i n Office of Inspector General Page 112 Chapter 18 November 1997. Therefore the original target date needs to be adjusted. HUD needs to take immed iate action to ensure the survey is conducted in order for the Authority to act on the results. The Deputy Executive Director for Community Relation s and Involvement suggested that t he Agreement's target date be revised to January 31, 1998. We believe January 31 , 1998 is a reasonable date that gi ves HUD and the Authority time to analyze the results of the surveys. We recommend HUD and the Authority adjust the target date to complete the resident surveys to January 31, 1998. We recommend HUD assures the Authority takes appropriate action based upon the results of the surveys. The Authority's Deputy Executive Director of Community Management's Comments Relations and Involvement said, "I am in agreement wit h your observations, howe ver, I offer the following comment concerning your recommendation that the Authorit y continue to identify government, non-profit, and privat e sector agencies to form partnerships that will support th e Authority's resident training and employment program. HUD should also take on the responsibility of helping th e Authority to identify resources and work to creat e interdepartmental agreements on the Federal level whic h would facilitate Public Housing Authorities access to non- HUD Federal dollars and programs. We agree with the Deputy Executive Director's comment . Evaluation of Comments Our Chapter on Alternative Funding Sources contains a recommendation for HUD to assist the Authority to locate and obtain alternate private or public funding sources (see page 118). Page 113 Office of Inspector General Chapter 18 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 114 Chapter 19 Alternative Funding Sources In 1995 and 1996 the Chicago Housing Authority received cuts of mor e than $86 million in HUD funding of operating subsidies and comprehensive grants. As a result, the Authority has found it increasingly important to pursue assistance and funding from State, local, private, or othe r Federal sources. The Authority included goals and strategies in its Lon g-Term Plan, dated February 15, 1996, and its June 21, 1996 draft Memorandum of Agreement with HUD regarding alternative fundin g sources. The Plan contains the goal to explore alternative and innovative approaches to th e Authority's housing problems. T he strategy for this goal is to identify relationships and housing opportunities with public and private d evelopers and finance agencies. The Agreement contains the goal to increase working capital for purposes of maintaining cash flow. To accomplish the Agreement's goal, the Authority's strategy is to research and pursue alternative funding sources and grants. Public and Private Developers. The Authority received a Observations $50 million Hope VI grant from HUD in 1994 to pursue a redevelopment plan at Cabrini Green and the surroundin g area. To accomplish the plan, the Authority established a partnership with the City of Chicago. The partnership has resulted in a plan for a $1 billion redevelopment project. If the plan is carried out, the Cabrini Green area will b e reshaped into a mixed-income community. Th e redevelopment is expected to take at least ten years t o complete. The City of Chicago plans to contribute to th e partnership by selling 53 acres of its land to privat e developers. The Cabrini Green site and the land contributed by the City will be used as the site for the construction of 2,000 ne w residential units that combine town houses, single famil y homes, three-flats, mid-rises, a single-room occupanc y building, and othe r community support facilities. The plan calls for private developers, who have yet to be named, to sell approximately 1,400 units to unassisted individuals , with the remaining units to be used for public housing. The redevelopment plan also envisions public and privat e developers employing residents during the redevelopment process. As of August 23, 1996, 297 jobs have bee n created as a result of the redevelopment plan at Cabrin i Green. Additionally, the Authority expects another 25 0 jobs to be created. Page 115 Office of Inspector General Chapter 19 The Authority plans to use the homeownership program as part of its redevelopment activities. Private banks i n conjunction with FHA insurance funds will be used to turn qualified public housing tenants into homeowners. Th e redevelopment plan also calls for a new elementary an d high school, library, police station, park, shopping center , and community center. The Authority is planning to pursue similar efforts at its ABLA Homes, Henry Horner, an d Robert Taylor developments. We recommend that HUD monitors the Authority's efforts to pursue housing opportunities with public and private developers and provides necessary assistance to gain full participation and commitment of all parties involved. Funding Sources and Grants. The Authority i s aggressively pursuing funds from sources ou tside HUD. To accomplish this, the Authority created a Gran t Administration Department in June 1996. Previously, the External Affairs Department was responsible for th e Authority's grant application process. The Gran t Department identifies funds available from various State , local, Federal, and private agencies for resident initiative s and tenant services. The Grant Department also prepare s and submits grant and continuing funding applications . Obtaining additional funding to support resident initiatives and tenant services allows the Authority to concentrate its resources from HUD on maintenance and operations. In the past, the Authority's primary focus was on obtaining funding from obvious sources, such as HUD's Dru g Elimination Grants. Currently, the Grant Administratio n Department is extending its outreach to obtain funds t o create, maintain, improve, and expand the Authority' s Community Relations and Involvement programs an d services. Examples of the programs and services includ e resident employment and training, child care, and yout h sports and recreation. On July 18, 1996, the Grant Administration Departmen t submitted an application to the U.S. Department of Health and Human Services on behalf of the Authority's residen t organizations. The grant will assist the Communit y Office of Inspector General Page 116 Chapter 19 Relations and Involvement Division to administer a program to increase resident awareness about nutrition. The Authority has entered into partnerships with variou s non-profit organizations, resident managemen t corporations, and the City of Chicago. These partnerships are submitting grant requests for over $2.1 million to HUD, the Center for Disease Control, and the U.S. Department of Education. The funds will be used to help prevent intimate partner violence, hate crimes, and help youth at risk. Th e Authority is also developing a partnership with th e Muhammad Ali Economic Development Corporation t o help alleviate vacancy problems by getting privat e developers to help rehabilitate properties. Th e Development Corporation has a goal of raising $1 million for this effort. The Authority has committed to matchin g every two dollars raised with one dollar from it s Comprehensive Grant Program or Vacancy Reductio n Grant. The Deputy Executive Director for Communit y Relations and Involvement said, in connection with thi s program, 20 residents will be hired per development t o increase the Authority's resident employment and training initiatives. Several examples of grants the Authority has recentl y received include: $4.6 million from the State of Illinois ' Department of Human Services to develop nine child care centers for day care and Head Sta rt services; and $6 million from the U.S. Department of Agriculture for a summe r lunch program. The monies will help alleviate th e Authority's financial burdens and enable i t to better serve its residents. In the past, HUD was not an active participant in helpin g the Authority locate sources of funding outside of HUD . The Authority believes that HUD should be more active in helping them identify alternative funding sources. Th e Authority did not have a copy of "The Catalog of Federa l Domestic Assistance." The catalog is a government-wid e publication of Federal programs, projects, services, an d activities that provide assistance or benefits. We provided the 1996 edition of the catalog to the Author ity. In this time of shrinking resources, it is important for HUD to play a n active role in assisting public housing authorities obtai n Page 117 Office of Inspector General Chapter 19 alternative sources of funding in order to meet HUD's goal of providing decent, safe and sanitary housing. We recommend that HUD assures the Authority continues to aggressively pursue alternative funding sources. We recommend that HUD assists the Authority to locate and obtain alternate private or public funding sources. The Authority's Deputy Executive Director of Community Management's Comments Relations and Involvement said, "I am in agreement wit h your observations." Office of Inspector General Page 118 Chapter 20 Section 8 Program Prior reports issued during 1994 and 1995 by the Chicago Housing Author ity's Inspector General, independent public accountants, and a c onsultant showed the Authority's Section 8 Program had many problems. For example, waiting lists were not reliable and the staff lacked knowledge of the Section 8 requirements. The HUD Blueprint, dated June 11, 1995, contained a goal to immediately prepare and release a Request for Proposal t o contract out the operation of the Section 8 Program. On February 15, 1996, the Authority issued a Long-Term Plan that contains a goal to improve the Section 8 delivery network. The target date for the goal is June 30, 1997. The Authority's draf t Memorandum of Agreement, dated June 21, 1996, did not contain any goals or strategies relating to the Section 8 Program. Section 8 Program. HUD issued a Request for Proposa l Observations on June 28, 1995 to obt ain a firm to operate the Authority's Section 8 Program. Based upon the offers received, HUD selected Quadel Consulting Corporation to operate th e Section 8 Program. The A uthority and Quadel entered into a Letter Agreement on October 1, 1995 whi ch was followed by a contract on December 1, 1995. Quadel created a separate corporation called CHAC Inc. to operate th e Section 8 Program. Quadel is the parent company o f CHAC. Representatives from HUD and the Authorit y currently monitor CHAC to resolve problems and ensure it is meeting the terms of the contract. Actions taken by CHAC. The strategies in the Authority's Long-Term Plan are also service requirements of th e contract. As of June 30, 1996, CHAC has met or is o n schedule to meet the contract's requirements and the target dates established in the Long-Term Plan which ar e discussed below. The target dates range from March 1996 to December 2000. For example, CHAC: • Submitted a revised administrative plan on Novembe r 15, 1995 prior to the issuance of the Long-Term Plan . HUD approved the plan on March 29, 1996. Th e administrative plan contains the policies and procedures for operating the Section 8 Program. The target date for completing this strategy was March 31, 1996. • Developed and implemente d a leasing schedule prior to the issuance of the Long-Term Plan. HUD approve d Page 119 Office of Inspector General Chapter 20 the schedule on January 18, 1996. The schedul e outlines the Section 8 Program's annual goals. • Began training its staff in aspects of progra m administration in November 1995 prior to the issuance of the Long-Term Plan. CHAC is training its staff on its computer system, employee appraisals, progra m requirements, and customer service. CHAC als o implemented a certification program where al l occupancy specialists and inspectors must be certified. Each employee is tested and must pass an exam t o maintain their position. The target date for completing this strategy is June 30, 1997. • Began updating the waiting list which was previousl y maintained by the Authority. On July 5, 1996, CHAC mailed approximately 47,000 letters to obtain update d information from persons on the waiting li st. Responses are due by August 2, 1996 with the revised waiting list due to be completed by August 30, 1996. Although the Long-Term Plan does not contain specifi c strategies related to tenant reexaminations and uni t inspections, the contract contains requirements for initia l and periodic inspections of units to enforce complianc e with HUD's Housing Quality Standards. Unde r the terms of the contract, CHAC is required to reexamine and inspec t one-twelfth of the Section 8 units each month startin g March 1, 1996. We found t he required reexaminations and inspections were being completed as required. Tracking of recertifications. CHAC utilized th e Authority's computer system until December 31, 1995, a t which time it converte d to its own computer system. Since that time, CHAC has been unable to use its compute r system to determine if required recertifications have bee n completed. CHAC's Memory Lane System which track s the annual reexaminations and M-track sy stem which tracks the inspection information were not integrated. CHA C immediately remedied the situation using manua l procedures; however, manual procedures are no t as efficient or effective as the automated system. Quadel assigned a computer consultant to coordinate the occupancy an d inspection activities to produce a report that will provid e Office of Inspector General Page 120 Chapter 20 accurate annual recertif ication information. The consultant expects to produce an accurate report by September 30 , 1996. We recommend HUD and the Authority verifies that CHAC develops a method to produce an accurate recertification report by September 30, 1996. Quality control. CHAC needs to improve the accuracy of its file reviews and inspections. In January 1996, CHA C was assisted by Abt As sociates to develop a quality control policy. Abt developed the policy on January 31, 1996 and CHAC immediately implemented it. The policy include d an emphasis on tenant file reviews and inspections. Fo r evaluating Quadel's performance, the contract allows for no more than: (1) a 5 percent error rate for the calculation o f tenants' contributions; and (2) a 10 percent error rate o f units reinspected for Housi ng Quality Standards within two months of approval. An error in the calculation of the tenants' contribution s consists of: an overstatement or an understatement of th e tenants' income or allowances ; or a mathematical error. An error of units inspected consists solely of units that ar e reinspected two months after CHAC's inspection an d approval which still have an Housing Quality Standar d violation existing. All errors are required to be corrected. Abt Associates issued the first quality review report on July 5, 1996 which summarized the weekly review result s through June 21, 1996. The weekly reviews ar e communicated on CHAC's: (1) file review checklists; (2 ) file review forms; (3) case logs; (4) inspection audit logs ; and (5) quality inspection reports. Abt's report showe d CHAC exceeded the error rates by approximately 2 0 percent for both file reviews and inspections. Once th e errors were detected and reported, CHAC corrected th e deficiencies. In the past, the Authority did not track the results of it s quality control reviews. CHAC is now tracking the results of the quality control reviews that are conducted on a weekly basis. The weekly reviews showed that CHAC' s error rates have not decre ased since the review process was Page 121 Office of Inspector General Chapter 20 initiated. As a result, CHAC followed up with its staff , emphasizing the errors in order to eliminate futur e occurrences, and has provided training to address the major errors. CHAC also used the results when it evaluated it s staff in May 1996. The attention to quality control results should help CHAC to improve its quality. We recommend HUD and the Authority assures CHAC continues to track its quality control reviews and implements appropriate actions to reduce its error rates. Computer terminals. As of June 30, 1996, CHAC did not have sufficient computer terminals to effect ively operate the Section 8 Program. Only 10 computer terminals wer e available to serve a staff of 46. CHAC only had 1 0 computers because its staff was not fully trained. CHA C planned on phasing in additional computers as staf f received training. On May 31, 1996, CHAC ordered 3 5 new computer terminals. Fifteen of these were delivered on June 15, 1996. As of July 8, 1996, five were installed. The remaining 20 terminals will be delivered, and all terminals will be installed by August 31, 1996. We recommend HUD and the Authority assures CHAC received and installed the 35 computers. We recommend HUD and the Authority assures CHAC fully trains its staff as expeditiously as possible but no later than the June 30, 1997 Long-Term Plan target date. Program effectiveness. Although CHAC is makin g progress to deliver an effective Section 8 Program, th e Long-Term Plan and the Memorandum of Agreement d o not contain an overall goal and target date to evaluate th e program's effectiveness and make necessary adjustment s after the individual goals that are not on-going ar e implemented. The non-continuous strategi es outlined in the Authority's Long-Term Plan consist of the following: (1 ) conducting housing assistance opportunities seminars fo r the Authority's staff and tenant groups; (2) developing and implementing an outreach program for new landlords; and (3) pursuing additional funding . These strategies should all Office of Inspector General Page 122 Chapter 20 be implemented by June 30, 1997. An overall assessment of the program after it is implemented is important to give HUD and the Authority assurance the problems that led to the decision to contract out have all been corrected. We recommend HUD and the Authority amend their Memorandum of Agreement to add a strategy to assess the effectiveness of contracting out the Section 8 Program and include a target date of December 31, 1997 for this action. The Authority's Deputy Executive Director of Operation s Management's Comments said, "We concur with the draft observations and th e associated recommendations. Accordingly, the Chicag o Housing Authority will incorporate the offere d recommendations in our overall planning process." Page 123 Office of Inspector General Chapter 20 THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 124 Appendix A Recommendations Following is a consolidated list of our recommendations to HUD. HUD needs to aggressively follow the Authority's progress in correcting its problems and: 1A. Assure the Authority develops procedures an d Security controls to establish and evaluate performanc e measures for each security initiative undertaken . Performance measures should be established fo r each initiative outlined in the Blueprint , Memorandum of Agreement, Long-Term Plan, and the Buracker Report. 1B. Assure the Authority immediately starts to develop site-based security plans for the Cabrini Green, Ida B. Wells, Altgeld Gardens, and ABLA Home s developments. 1C. Monitor the Authority to ensure it develops all site- based security plans by December 31, 1997. 1D. Assure the Authority develops house rules b y December 31, 1996 and immediately begins t o enforce the rules. 1E. Complete the Memorandum of Agreement an d provide the Authority with a firm funding target so the Authority can make decisions regardin g the most effective way to cut costs while maintaining th e highest level of security possible. 1F. Allow the Authority sufficient time to evaluate it s security initiatives in accordance wit h recommendation 1A before requiring adherence to a cost reduction plan. 2A. Require the Authority to develop a comprehensiv e Modernization/Redevelop modernization/redevelopment plan for all of it s ment of Housing developments once the viability assessment an d marketing plan have been completed. The pla n should consider and incorporate the results of th e marketing study and viability assessment . Specifically, the plan should identify developments by categories such as stable, high-needs and non - viable developments. In addition, the plan shoul d identify all planned demoli tion and rehabilitation by Page 125 Office of Inspector General Appendix A building with the costs necessary to make th e repairs. 2B. Assure the Authority de velops controls to ensure all plans, including the comprehensive plan to b e developed, are consistent. 2C. Continue to closely watch the Authority's progres s in implementing its modernization an d redevelopment efforts. HUD should provid e technical assistance to ensure the modernization and redevelopment goals are fully implemented. 2D. Assure the Authority performs a viabilit y assessment with a 20-year cash needs forecast b y December 31, 1996 and completes it s Memorandum of Agreement goal to develop a marketing plan b y March 31, 1997. 3A. Assure the Authority reviews i ts work order policies Work Order System and procedures, develops procedures to operate the system effectively, and inc ludes the new procedures in its Maintenance Manual. 3B. Assure the Authority promptly distributes th e revised Maintenance Manual to all applicabl e personnel. 3C. Assure the Authority trains all its maintenanc e superintendents and supervisors on work orde r procedures by December 31, 1996. 3D. Assure the Authority: (1) develops procedures t o distribute weekly activity reports to Developmen t Managers and for Development Manag ers to use the weekly reports to man age their work order backlog; and (2) implements the use of performanc e standards to monitor staff performance. 3E. Coordinate with the Authority to establish a targe t date to review the work order backlog, asses s staffing needs, and develop a "get well" plan if the backlog situation will result in less than a passin g Public Housing Management Assessment Program Office of Inspector General Page 126 Appendix A grade. This review should be conducted no late r than June 30, 1997. 4A. Assure the Authority completes its viabilit y Preventive Maintenance assessment by December 31, 1996 and immediately conducts or contracts to have a preventiv e maintenance needs assessment completed for eac h development and develops a funding plan for th e repair of maintenance deficiencies. 4B. Assure the Authority uses the preventive need s assessment to develop and implement a preventive maintenance schedule by June 30, 1997. 5A. Assure the Authority implements wee kly tracking of Vacancy Reduction/Unit unit turn-around from date of vacancy to re - Turnaround occupancy and implements a reporting system t o track vacant unit turnaround at the developmen t level by December 31, 1996. 5B. Assure the Authority expeditiously identifies an d deprograms all non-dwelling units. 5C. Assure the Authority develops procedures to verify that units completed under the Vacancy Reductio n Program meet HUD's Housing Quality Standards. 5D. Assure the Authority develops coordinatio n procedures between the Vacancy Reductio n Department, Development Managers, and th e Occupancy Department. The procedures shoul d ensure units are repaired on the b asis of demand and applicable personnel are aware of projecte d completion dates so units can be pr omptly occupied. 5E. Assure the Authority's Vacancy Reductio n Department develops a plan that shows how it will complete the 2,857 units required by its Vacanc y Reduction grant. The plan should identify the units that will be completed, and include the estimate d costs for each unit. Funding for Maintenance 6A. Closely watch th e Authority's progress in achieving and Modernization the milestones and implementing the strategy t o Page 127 Office of Inspector General Appendix A target and link up with appropriate resources. Provide any technical assistance the Authority may require i n order to achieve the milestones and implement th e strategy. 6B. Assure the Authority completes its viabilit y assessment by December 31, 1996 and immediately coordinates its modernization and capita l improvement programs with its 1996-199 7 Comprehensive Grant Program plan. 6C. Work closely with the Authority to assure it closes out all of the open modernization programs related to the Comprehensive Improvement Assistanc e Program and Comprehensive Grant Program that are over three years old. 7A. Assure the Authority develops thorough , Annual Inspections comprehensive inspection procedures and includes the new procedures i n the Maintenance Manual and Housing Quality Standards Training Manual. 7B. Assure the Authority identifies the funds an d implements a new timetable for initiating the jo b order contracting system. Once the timetable i s complete, monitor the Authority to assure that th e job order contracting system is properl y implemented. 7C. Assure the Authority conducts quality contro l reviews of inspections to ensure the inspections are accurately conducted and inspection forms ar e properly completed. 7D. Assure the Authority promptly evaluates eac h development to determine if all annual inspectio n forms, competed after April 1, 1 996 were sent to the Customer Service Center to initiate work orders. 7E. Assure the Authority implements controls tha t ensure work orders are written to addres s deficiencies identified by all future inspections. Housing Management Functions Office of Inspector General Page 128 Appendix A 8A. Monitor the Authority's progress in completing its Long - Term Plan strategies to: implement development-base d resource management; participate in the development an d review of uniform fi eld-based policies and procedures; and develop a uniform property management reporting process. Should the Authority deviate from the Long-Term Pla n strategies, HUD should pro vide technical assistance or take other corrective actions. 8B. Closely watch the Authority's progress i n implementing the Memorandum of Agreemen t strategies to: improv e communications and internal reporting between the site managers and the central office; and create site-based managemen t implementation plans for each development . Provide any technical assistance the Authority may require to assure the strategies are implemented on schedule. 8C. Coordinate with the Authority to establish a revised target date to identify all major housing function s and assure the Authority allocates sufficien t resources to accomplish this strategy. 8D. Closely monitor the Authority's progress to meet the housing management improvement strategies an d provide any assistance necessary to help evaluat e the functions, and improve their effectiveness an d efficiency. 8E. Coordinate with the Authority to make the strategy of identifying opportunities to delegate management activities a continuing effort. 8F. Coordinate with the Authority to establish a strategy to review the results of actions taken to delegat e responsibilities to the developments. We suggest a review be conducted ap proximately one year after a responsibility is delegated. 9A. Assure the Authority fills its home visit inspecto r Admissions and Evictions positions as expeditiously as possible. Page 129 Office of Inspector General Appendix A 9B. Assure the Authority ex tends its contract to conduct home visits until it fills the home visit inspecto r positions. 9C. Assure the Authority develops procedures tha t ensure all applicants are screened using the ne w screening procedures before being placed in a unit. The procedures should state that applicants will not be screened upon initial interview if units are no t available, and that screening sho uld be conducted as close to the time of occupancy as feasible. 9D. Assure the Authority coordinates effo rts with HUD's and its legal department to provide a consisten t application of the Gautreaux decrees' requirements. Guidelines supporting interpretations should b e developed and application of the computerize d waiting list should reflect the guidelines. 9E. Assure the Authority develops procedures fo r Development Managers and the Social Service s Division to coordinate on potent ial evictions and the need for social services. 9F. Assure the Authority's lease contains the correc t provisions outlin ed in Public Housing Notice 96-14 and the Authority uses the lease. 9G. Assure the Authority completes lease training for all residents by September 30, 1996, and upo n approval, uses the lease for all new tenants and for all annual recertifications. 9H. Assure the Authority makes the new handboo k available to all residents when they recertify thei r leases. 9I. Assure the Authority adopts a tenant handbook an d develops the site-based resident orientation manual by September 30, 1996, and implements a site-base d resident orientation process by December 31, 1996. 10A. Assure the Authority continues to develop source s Rent Collections for orientation programs and financial services t o Office of Inspector General Page 130 Appendix A assist its tenants to become more self-sufficient. HUD should provide assistance in identifying and developing the sources. 10B. Assure the Authority establishes controls to ensure all uncollectible accounts are r eferred each month to the collection agency. 11A. Assure the Autho rity establishes written procedures Procurement and outlining the emergency procurement process an d Contracting incorporates the procedures in the Maintenanc e Manual. 11B. Assure the Authority establishes procedures an d controls to verify that items purchased through th e open hardware accounts are for emergenc y purposes. 11C. Assure the Authority implements procedures t o notify reviewing officials of the terms of the ope n supply and service accounts' purchase agreements. 11D. Assure the Authority requires its vendors to sho w discounts received on applicable invoices so th e Authority has assurance it is receiving the discounts to which it is entitled. 11E. Assure the Authority reviews its purchas e agreements to ensure they reflect the correc t discounts. 11F. Closely watch the Authority's progress i n implementing the strategies for improving th e procurement process by March 31, 1997. Provid e any technical assistance the Authority may requir e in order to achieve the goal and target date. 11G. Assure after all strategies have been implemented , the Authority assesses its procurement process t o ensure the problems the strategies were created t o eliminate have been corrected or takes actions t o make additional changes. This should b e accomplished by September 30, 1997. Page 131 Office of Inspector General Appendix A 11H. Coordinate with the Author ity to assess the status of the recommendations in HUD's Au gust 1995 review and to ensure agreement with actions or lack o f actions taken to correct the problems th e recommendations were made to address. 11I. Assure the Authority develops procedures t o conduct a periodic analysis of its contra cting process and initiates actions necessary to improve th e process. 12A. Closely follow the Authority's progress i n Accounting Systems And implementing the new accounting system an d Controls provide any assistance necessary to ensure th e system is fully implemented by December 31, 1996, and that a site-based budget is achieved b y December 31, 1997. 12B. Assure written policies an d procedures are issued as quickly as practical after each accounting functio n is implemented. 13A. Assure the Authority evaluates and selects th e Management Information budget and payroll modules immediately, so th e System modules can be implemented by the December 31, 1996 target date to have a functioning integrate d management information system. 13B. Assure the Authority establishes controls an d procedures to complete the implementation of it s integrated management information system b y December 31, 1996, and to periodically assess it s information needs. 13C. Assure the Authority establishes controls an d procedures to ensure all applicable employee s receive software training by Decembe r 31, 1996, the day the new integrated system will be full y implemented. 13D. Assure the Authority completes the revisions of its policies and procedures and implements all ne w security procedures by December 31, 1996. Office of Inspector General Page 132 Appendix A 14A. Assure the Authority monitors the privat e Asset Management management firms to ensure the developments ar e maintained in an adequate manner and according to the management contracts, and that the Authorit y takes appropriate action if firms do not properl y manage the developments. 14B. Closely watch the Authority's progress to privatize 15,000 units by December 31, 1996 to ensur e privatization contracts are providing acceptabl e housing at a reasonable cost. 14C. Assure the Authority establishes coordinatio n procedures between Private Managemen t Administration and Department of Finance fo r Public Housing/Private Manag ement for monitoring the private firms. 14D. Assure the Authority executes contracts with th e legal and actuarial firms selected for award. 14E. Assure the Authority properly overse es the contracts awarded for the pension fund and takes appropriate action if the contractors do not effectively perform the required services. 14F. Assure the Authority establishes controls to ensure the deferred compensation contract is adequatel y monitored and appropriate actions are taken if th e firm under contract is not properly managing th e deferred compensation program. 15A. Assure the Authority aggressively monitors th e Risk Management workman's compensation contract and take s appropriate actions if the firm does not properl y manage the program. 15B. Assure the Authority periodically conducts a n analysis to determine if it is more cost effective t o contract out the administration of the workman' s compensation program versus the Authorit y administering the program in-house. Page 133 Office of Inspector General Appendix A 15C. Assure the Authority initiates safety training for its residents by September 30, 1996. 15D. Assure the Authority develops procedures to trac k hazardous conditions until the conditions ar e eliminated. 15E. Assure the Authority develops procedures t o periodically assess its risk management progra m and makes changes to address new conditions. 16A. Assure each of the Authority's managers have been Personnel certified by the March 31, 1997 Memorandu m Agreement target date for assessing and developing staff skill levels. 16B. Assure the Authority develops and implement s strategies to address: (1) the skill level of all it s staff, and (2) the issue of staff who do not mee t minimum required skill levels. 16C. Assure the Authority develops an effectiv e recruiting strategy that properly assesses th e qualifications of potential employees. 16D. Assure the Authority appoints qualified instructors and implements the core courses by the September 30, 1996 target date established in th e Memorandum of Agreement. 16E. Assure the Authority establishes and implement s procedures to consolidate the tracking of trainin g received by its employees. 16F. Monitor the Authority to ensure it completes th e implementation of the compen sation system and job descriptions by March 31, 1997. 17A. Assure the Authority fol lows the requirements of its Resident Program contracts and ensures all contract extensions ar e Delivery Systems made before the original contract expires and are in writing. Office of Inspector General Page 134 Appendix A 17B. Assure the Authority: (1) executed contracts wit h the urban planners for Dearborn Homes, Rober t Taylor B, Wentworth Gardens, Hilliard Homes , Lathrop Homes, Washington Park, and Trumbal l Park; and (2) ensures the remaining eight Loca l Advisory councils select an urban planner a s expeditiously as possible but no later th an December 31, 1996. 17C. Assure the Authority established policies an d procedures for its Development Initiatives Division by September 30, 1996. 17D. Assure the Authorit y establishes a transition facility at the ABLA Homes development when th e necessary funding is obtained and explore s establishing additional transition facilities at othe r developments based upon the needs of the residents. 17E. Assure the Authority monitors the contract with the Educational Training and Enterprise Center t o ensure it receives the required servic es by December 26, 1996. 17F. Assure the Authority takes appropriate action b y January 31, 1997 based upon the Educationa l Training and Enterprise Center's report. Th e Authority should only select, for continued use , those existing services and delegate agencies tha t are shown to best meet its residents' needs. 17G. Assure the Authority performs the following step s related to potential/future services and delegat e agencies: (1) identifies and evaluates their delivery systems by January 31, 1997; (2) conducts a cost/benefit analysis of their service deliver y systems by June 30, 1997; (3) selects those that best meet the residents' ne eds not currently addressed by September 30, 1997; and (4) monitors services and delegate agencies to ensure the residents needs ar e being addressed. Economic Development Opportunities for 18A. Assure the Authority continues to emphasize th e Residents development of joint venture agreements betwee n Page 135 Office of Inspector General Appendix A the resident owned companies and private secto r businesses. 18B. Assure the Authority works to expeditiousl y complete its pending contracts and continues t o explore other contracts with the resident owne d companies in order to reach the yearly goal of 2 5 contracts. 18C. Assure the Authority monitors the construction and service contractors to ensure: (1) residents ar e receiving the employment and traini ng opportunities as required; or (2) the appropriate amounts ar e withheld from contractors for failing to meet th e Section 3 requirement. 18D. Assure the Authority continues to identif y government, non- profit, and private sector agencies to form partnerships that will suppo rt the Authority's resident training and employment programs. 18E. Coordinate with the Authority to adjust the targe t date to complete th e resident surveys to January 31, 1998. 18F. Assure the Authorit y takes appropriate action based upon the results of the surveys. 19A. Monitor the Authority's efforts to pursue housin g Alternative Funding opportunities with public and private developers and Sources provide necessary assistance to gain ful l participation and commitment of all partie s involved. 19B. Assure the Authority continues to aggressivel y pursue alternative funding sources. 19C. Assist the Authority to locate and obtain alternat e private or public funding sources. 20A. Coordinate with the Authority to verify that CHAC Section 8 Program develops a method to produce an accurat e recertification report by September 30, 1996. Office of Inspector General Page 136 Appendix A 20B. Coordinate with the Authority to assure CHA C continues to track its quality control reviews an d implements appropriate actions to reduce its erro r rates. 20C. Coordinate with the Authority to assure CHA C received and installed 35 computers. 20D. Coordinate with the Authority to assure CHAC fully trains its staff as expeditiously as possible but n o later than the June 30, 1997 Long-Term Plan target date. 20E. Coordinate with the Authority to amend th e Memorandum of Agreement to add a strategy t o assess the effectiveness of contracting out th e Section 8 Program and include a target date o f December 31, 1997 for this action. Page 137 Office of Inspector General Appendix A THIS PAGE LEFT BLANK INTENTIONALLY Office of Inspector General Page 138 Appendix B Distribution Director, Office of Troubled Agency Recovery (2) Secretary's Representative Midwest Director, Public Housing Division, Illinois State Office (2) Director Accounting Division, Midwest Field Controller, Midwest Assistant General Counsel, Midwest Public Affairs Officer, Midwest Assistant to the Deputy Secretary for Field Management, SC (Room 7106) Acquisitions Librarian, Library, AS (Room 8141) Deputy Chief Financial Officer for Operations, FO (Room 10166) (2) Chief Financial Officer, F (Room 10166) (2) Director, General Management Division, PMG (Room 4216) Comptroller/Audit Liaison Officer, PF (Room 4122) (3) Associate General Counsel, Office of Assisted Housing and Community Development, GC (Room 8162) Assistant Director in Charge, U.S. GAO, 820 1st St. NE, Union Plaza, Building 2, Suite 150, Washington DC, 20002 (2) Page 139 Office of Inspector General
Chicago HA, Chicago, IL
Published by the Department of Housing and Urban Development, Office of Inspector General on 1996-09-30.
Below is a raw (and likely hideous) rendition of the original report. (PDF)