oversight

Benton Township Housing Comm., Benton Harbor, MI

Published by the Department of Housing and Urban Development, Office of Inspector General on 1995-10-05.

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

Issue Date
October 5, 1995
Audit Case Number
96-CH-202-1001

TO: Joann Adams, Acting Director, Office of Public Housing, Grand
   Rapids Area Office

FROM: Dale L. Chouteau, District Inspector General for Audit, Midwest

SUBJECT: Benton Township Housing Commission
    Low-Income Housing Program
    Benton Harbor, Michigan

We completed an audit of the Benton Township Housing Commission's Low-
Income Housing Program. We selected the Commission for audit based on a
program of periodic reviews of Public Housing Authorities and input from
the Grand Rapids HUD staff. The audit objectives were to determine
whether the Commission effectively and efficiently administered its low-
income public housing activities in compliance with HUD's requirements.

The Commission generally administered its Low-Income Housing Program
according to HUD's requirements. The Commission maintained its occupied
units in decent, safe and sanitary condition; properly managed its
nonexpendable equipment; and properly maintained its accounts receivable
balances and occupancy levels. The Commission could, however, further
improve its operations by: (1) reducing the time to prepare and lease
vacant units; (2) assuring its travel policy is comparable to the local
public practice; and (3) charging only supported payroll costs to the
Comprehensive Improvement Assistance Program.

Within 60 days, please provide us, for each recommendation made in this
report, a status report on: (1) the corrective action taken; (2) the
proposed corrective action and the date to be completed; or (3) why
action is considered unnecessary. Also please furnish us copies of any
correspondence or directives issued because of the audit.

Should your staff have any questions, please have them contact me at
(312) 353-7832.

Executive Summary

We conducted an audit of the Benton Township Housing Commission's Low-
Income Housing Program. Our objectives were to determine whether the
Commission effectively and efficiently administered its Low-Income
Housing activities in compliance with HUD's requirements.

The Commission generally administered its Low-Income Housing Program
according to HUD's requirements. The Commission maintained its occupied
units in decent, safe and sanitary condition; properly managed its
nonexpendable equipment; and properly maintained its accounts receivable
balances and occupancy levels. However, as shown in the findings, the
Commission could further improve the administration of its Low-Income
Housing Program to ensure compliance with HUD's requirements and to
increase efficiency and effectiveness.

The Commission Took Too Much Time To Prepare and Lease Units

The Benton Township Housing Commission took excessive time to prepare and
lease its vacant units. The Commission's average unit turnaround time
was 145 days between October 1994 and June 1995. The Commission also
incorrectly certified to HUD that its average turnaround time was 15 days
between October 1993 and September 1994. HUD Regulations require the
Commission to maintain an average turnaround time of 30 days, with a goal
of 10 days. The Commission did not give priority to preparing vacant
units. As a result, the Commission did not maximize rental income and
assistance provided to needy families.

The Commission's Travel Policy Needs Revision

The Benton Township Housing Commission's travel policy was not comparable
to the local public practice, as required by HUD. The policy allowed
subsistence reimbursement for meals of $65 per day, whereas the local
city allowed a maximum of $38 per day. The Executive Director believed
the Commission's policy was valid since the Board of Commissioners
determined it was comparable to other Commissions' policies. The
Commission's policy was not economical and cost efficient.

The Commission Improperly Charged Payroll Costs

The Benton Township Housing Commission charged excessive payroll costs to
the Comprehensive Improvement Assistance (modernization) Program.
Modernization funds that were available at year end were inappropriately
divided between the payroll costs of three employees. The Commission
charged $67,479 to the Program. The employees' time records supported
that costs of only $11,409 should have been charged to the Comprehensive
Improvement Assistance Program. As a result, $56,070 of modernization
funds were not used for the intended purposes of making physical and
management improvements at the Commission. Instead, the Commission used
the funds to inappropriately subsidize its Low-Income Housing operations.
Recommendations

We recommend that the Director of the Public Housing Division assures the
Housing Commission implements procedures and controls to assure its:
units are prepared and leased in a timely manner; Public Housing
Management Assessment Program certifications are fully supported; travel
policy complies with the City of Benton Harbor; and modernization
programs are only charged for actual costs.

We provided our draft findings to the Commission's Executive Director and
HUD staff during the audit. We held an exit conference on August 24,
1995 with the Commission's Executive Director. The Housing Commission
provided written comments to our findings. We considered the comments in
preparing our report.

Introduction

We completed an audit of the Benton Township Housing Commission. The
Commission was established in 1960 under the laws of the State of
Michigan. The Commission is a public housing agency organized to
efficiently and effectively provide decent, safe and sanitary housing to
low-income families.

A five-member Board of Commissioners governs the Housing Commission. The
Benton Township Supervisor appoints the board members to staggered five-
year terms. The Executive Director is responsible for day-to-day
operations.

The Housing Commission operates and maintains 300 low-income housing
units at two projects. Plaza Manor contains 100 elderly units. Blossom
Acres contains 160 family units and 40 elderly units. The Commission
also manages 75 Section 8 units.

The Commission received $322,482 in operating subsidies for fiscal year
1994. The Commission also received $3,229,000 for the Comprehensive
Improvement Assistance Program for fiscal years 1991 and 1992. In 1993,
HUD approved the Housing Commission's Five-Year Comprehensive Grant
Program with annual funding of $505,220 for modernization. In 1994, HUD
increased the annual funding to $544,562.

The Commission's books and records are at 1216 Blossom Lane, Benton
Harbor, Michigan. Sammie Smith is the Executive Director. The Board of
Commissioners President is James Ray.

Audit Objectives
Our audit objectives were to determine whether the Commission effectively
and efficiently administered its Low-Income Housing Program according to
HUD's requirements.

Our specific objectives were to determine whether the Commission:

-- Maintained decent, safe and sanitary units;

-- Properly managed its non-expendable equipment;

-- Properly maintained accounts receivable balances and occupancy
   levels;

-- Prepared and leased its vacant units timely;

-- Maintained adequate support for its Public Housing Management
   Assessment Program certification;

-- Maintained a travel policy according to HUD's requirements; and

-- Assured that payroll costs were properly allocated to its various
   programs.

Audit Scope and Methodology

To obtain background information, we interviewed HUD's staff from the
Grand Rapids Area Office's Public Housing Division. At HUD's Grand
Rapids Office, we also reviewed independent audit reports, operating
budgets, statements of operating receipts and expenditures, and Public
Housing Management Assessment Program reports.

To assess the adequacy of the Commission's operations, at the
Commission's Office, we interviewed the Executive Director and other
appropriate staff. We also reviewed records related to vacant unit
preparation, travel policies, travel expense reports, Public Housing
Management Assessment Program certifications, work orders, inventory
records, applicant waiting lists, accounts receivable and occupancy
reports, and unit inspection reports. We inspected 10 units to assess
their condition.

The audit covered the period from October 1, 1993 through March 31, 1995.
We extended the audit period as necessary. We did the on-site audit work
between May and August 1995.

We conducted the audit in accordance with generally accepted government
auditing standards.

We provided a copy of this report to the Benton Township Housing
Commission's Board President.

Finding 1

The Commission Took Excessive Time To Prepare And Lease Vacant Units

The Benton Township Housing Commission took excessive time to prepare and
lease its vacant units. The Commission's average unit turnaround time
was 145 days between October 1994 and June 1995. The Commission also
incorrectly certified to HUD that its average turnaround time was 15 days
between October 1993 and September 1994. HUD's Regulations require the
Commission to maintain an average turnaround time of 30 days, with a goal
of 10 days. The Commission did not give priority to preparing vacant
units. As a result, the Commission did not maximize rental income and
assistance provided to needy families.

HUD Requirements

HUD Handbook 7460.7 REV-1, Field Office Monitoring of Public Housing
Agencies, defines unit turnaround as a Performance Standard for
maintenance operations. Paragraph 5-2 (c) requires the Commission to
complete vacant unit turnaround in an average of no more than 30 calendar
days, with a goal of 10 days.

Unit turnaround is an operations indicator under Handbook 7460.5, Public
Housing Management Assessment Program. Paragraph 6-2 E 10(b) defines the
turnaround time as including the time a unit is vacated until a new lease
is in effect. Under the Assessment Program, unit turnaround is one of
the seven performance indicators that public housing agencies must
certify to HUD.

HUD Regulation 24 CFR, 901.100 (b)(2) requires public housing agencies to
maintain documentation that verifies all certified indicators.
Documentation should be retained for three years.

Turnaround Time Exceeded 30 Days

The Benton Township Housing Commission did not prepare and lease its
vacant units within 30 days, as required by HUD. Between October 1, 1994
and June 30, 1995, the Commission averaged 145 days to prepare and lease
22 vacant units. The average time to prepare a unit for occupancy was
102 days. The average time to lease a unit was an additional 43 days and
the range of the total time was from 21 to 335 days. The following chart
shows the number of units and the range of days they were vacant:

Days Vacant    Number of Units
 01-30          1
 31-60          2
 61-90          2
 91-180         12
181-360          5

Delays Occurred in Preparing and Leasing Vacant Units

The Executive Director said delays in unit turnover occurred because
maintenance personnel were required to complete work at occupied units
before they worked on vacant units. He said he had inadequate staff to
repair the unusual increase in vacancies that occurred in 1994. He also
said five-bedroom family and elderly efficiency units were difficult to
rent. Our audit showed that although the Commission had an increase in
turnover, it was exceeding the HUD standard of 30 days by 68 days before
the increase. The Commission's maintenance staff was comparable in
number to other commissions of its size. Additionally, of the 22 units
vacated, only one was an efficiency unit and three were five-bedroom
units.

The Commission expended excessive time before it inspected units, wrote
work orders and assigned the units to its maintenance staff for repairs.
For example, Unit 515, a three-bedroom unit, was vacant for 167 days.
The Commission inspected the unit 19 days after it was vacated. It took
the Commission another 112 days to write the work orders and 36 days to
complete the maintenance work and lease the unit.

Once the Commission completed the maintenance work, it took excessive
time to lease units. After the completion of maintenance work, 11 of the
22 units vacated in 1994 to 1995 were waiting to be leased for over 21
days. The average waiting time for these 11 units was 79 days. One of
the 11 units was an efficiency apartment; however, an applicant was
available and had to wait 81 days to occupy the unit.

The Executive Director said he is in the process of implementing new
procedures to improve the unit turnaround time. The new procedures will:
set priorities for repairing vacant units; allow smaller families to live
in larger units when there are no applicants for the larger units; and
start an applicant's certification process at an earlier stage. We
believe these procedures, when implemented, will improve the unit
turnaround time.
The Commission Provided an Incorrect Certification

The Commission incorrectly certified to HUD that the average time it took
to prepare and lease its vacant units between October 1, 1993 and
September 30, 1994 was 15 days. The 15-day turnaround time earned the
Commission a grade of A on HUD's Public Housing Management Assessment
Program Report. We determined the average turnaround time was 98 days
for the 20 units that became vacant during the 12 months. The 98-day
turnaround time should have earned the Commission a Grade of F. Since
HUD believed the Commission had a score of A on this indicator, HUD did
not accurately assess the Commission's performance and make
recommendations for improvement.

The Commission did not have documentation that showed the basis for its
calculation or that supported the accuracy of the certification. The
Executive Director said he did not personally calculate the numbers, but
believed some units were excluded because of fire-damage, modernization
work or other HUD-approved reasons. Our review showed that no units
should have been excluded from the calculation.

Auditee Comments

Excerpts from the Executive Director's comments on our draft finding
follow.

The Executive Director concurs that HUD's regulations require the Housing
Commission to complete vacant unit turnaround in an average of no more
than 30 calendar days, with a goal of 10 days. This is, however, an
unrealistic goal. There are many variables that enter into turning a
unit around, such as the number of units vacated within a given period of
time, the size of the units, the condition of the units when finally
vacated, available materials, work that requires a licensed contractor,
available staff, etc. During the period of time in question, the Housing
Commission reached a high of 30 vacancies. With a staff of four
maintenance men and one working supervisor, it was impossible to meet a
30 day turnaround schedule.

OIG Evaluation of Auditee Comments

HUD requires the Housing Commissions to complete vacant unit turnaround
in an average of no more than 30 calendar days. Therefore, the Housing
Commission should try to achieve this goal. We considered the variables
that the Executive Director mentioned in his comments and still found the
time to prepare the units for occupancy was well in excess of the HUD
standard. There were no records to support that 30 units were vacant at
one time. Our audit showed 22 units were vacated between October 1, 1994
and June 30, 1995. The Executive Director did not provide comments to
explain why it took the Commission excessive time to inspect units, write
work orders, and lease units after completion of maintenance work.

Auditee Comments

During this year, modernization work was going on at Blossom Acres and
Plaza Manor. It made more sense to complete the modernization work while
the units were vacant. The Commission received approval from the Grand
Rapids HUD Office to use excess modernization funds from a previous
Comprehensive Improvement Assistance Program to contract out the work to
rehab the vacant units.

Because the units were being made ready for leasing under the
modernization programs, they were not considered in the Public Housing
Management Assessment Program report. There was no attempt to
misrepresent our unit turnaround nor to influence HUD's determination of
the Public Housing Management Assessment Program score for this
indicator. Scores are fine, but most important to the Commission is
operating and maintaining a well organized and managed Housing
Commission.

OIG Evaluation of Auditee Comments

Our review showed that there were no units that should have been excluded
from the average unit turnaround time calculation due to modernization or
rehabilitation work. HUD allows the Commission to exclude a unit from
the unit turnaround calculation if the approved modernization makes it
necessary to vacate the unit. The Commission did not have records to
show which units were required to be vacated because of the modernization
program. The Commission also did not have records to show which units it
included or excluded from its calculation of the Public Housing
Management Assessment Program unit turnaround calculation.

The units we reviewed did not have to be vacated to prepare them for
occupancy. For example, Unit 515 was vacant 167 days to make the
following relatively minor repairs: 25 pieces of floor tiles; two towel
bars; three outlet sockets and cover plates; three locks; one thermopane;
one toilet seat; sixteen shades and painting.

The purpose of maintaining the unit turnaround time of 30 days is not for
scoring purposes, but to maximize rental income and provide assistance to
needy families in an expeditious manner.
Auditee Comments

The Executive Director did not provide comments regarding
Recommendation 1A. The Director provided comments for Recommendations 1B
and 1C.

Recommendation 1B

The Commission has implemented the following procedures to speed up the
tenant certification process: The first working day immediately
following the day that an intention to vacate a unit is received, the
intention is recorded by the housing manager or his/her designee. From
the waiting list, the next three eligible applicants in line for the
particular size unit are determined. Immediate contact is made by mail
with each of the applicants. The letter contains a listing of all
information that the applicant must provide to the Commission to
determine final eligibility. An approximate date that the unit will be
available is established.

Recommendation 1C

For tracking and reporting purposes the Commission has implemented a
reporting procedure that is reviewed the beginning of each work week.
The Director provided two exhibits for tracking and reporting.

OIG Evaluation of Auditee Comments

Although the Executive Director said he was implementing new procedures
to improve turnaround time, his written comments did not reflect that he
was implementing procedures to address Recommendation 1A.

The tenant certification procedures and tracking procedures should, if
properly followed, reduce lease time and satisfactorily correct the
problem of inaccurate Public Housing Management Assessment Program
certifications.

Recommendations

We recommend that the Grand Rapids Office's Director of Public Housing
assures the Benton Township Housing Commission:

1A. Implements procedures and controls to inspect units and write work
  orders immediately after units are vacated.

1B. Implements procedures to start the certification process for new
   tenants when the Commission knows a unit will be vacated.

1C. Establishes procedures and controls to assure that all future Public
   Housing Management Assessment Program certifications are correct,
   adequately supported, and that documentation is retained.

Finding 2

The Commission's Travel Policy Needs To Be Revised

The Benton Township Housing Commission's travel policy was not comparable
to the local public practice, as required by HUD. The policy allowed
subsistence reimbursement for meals of $65 per day, whereas the local
city allowed a maximum of $38 per day. The Executive Director believed
that Commission's policy was valid since the Board of Commissioners
determined it was comparable to other Housing Commissions' policies. The
Commission's policy was not economical and cost efficient.

HUD Requirements

HUD Handbook 7401.7, Public Housing Authority Personnel Policies,
Paragraph 5-19, requires the Commission to adopt travel regulations that
are comparable to local public practice governing reimbursements of
travel expenses to Board members and employees. Payments should cover
only reasonable travel costs that are necessary to operate the public
housing program economically and efficiently.

Commission's Travel Policy

The Commission revised and adopted its travel policy in January 1994.
The Commission's policy states that for subsistence allowance, a
Commissioner, employee or authorized delegate travelling on official
business shall be allotted $65 per diem.

Travel Policy Was Not Comparable to Public Policy

The Commission's travel policy was not comparable to local public
practice regarding payments for meals and incidentals. The City of
Benton Harbor used the Federal rates to establish reasonable allowances
for meals and incidentals. Using the Federal rates, a traveller may be
reimbursed from $26 to $38 a day depending on the location of travel.
The Commission allowed $65 per day for meals at any location.

The Executive Director said in January 1994 the Commissioners requested
and approved the increase in the meals allowance from $25 to $65 a day.
He said the Commissioners determined that per diem subsistence allowance
between $55 and $65 was common among other public housing agencies. We
verified the rate other commissions in the vicinity were paying and found
one was paying $60 a day; however, two others were paying $35 and $36 a
day. HUD requires the Commission's rate to be comparable to the local
public practice, not other housing commissions.

Between January 1994 and May 1995, the Commission processed and paid 82
reimbursement vouchers that included claims for meals at the rate of $65
per day. The travel was to locations in Michigan, Indiana, Ohio,
Florida, California, Illinois, and the District of Columbia. The Housing
Commission reimbursed travelers $18,915 for 291 temporary duty days.
Using the City of Benton Harbor's maximum rate of $38 per day, the
reimbursement would have been $11,058. As a result, the Commission paid
excessive costs of at least $7,857.

Auditee Comments

Excerpts from the Executive Director's comments on our draft finding
follow. Appendix A contains the complete text of the comments

The Board of Commissioners have consented to revise the travel policy.
The revised travel policy will reflect actual reasonable expenses
incurred rather than the $65 per diem. Travel expenses must be
documented and all meals $20 and over must be verified with a receipt.
The revised policy will reflect the norms of the housing industry and the
local governing body, Benton Charter Township. A committee has been
appointed to revise the travel policy and make recommendations to the
board at the October 1995 meeting. A review copy will be forwarded to
the U.S. Department of Housing and Urban Development, Grand Rapids
Office.

OIG Evaluation of Auditee Comments

The Commission's plan to revise its travel policy should adequately
resolve Finding 2 if the Commission's per diem rates do not exceed those
established by the City of Benton Harbor. The Benton Charter Township's
policy is general and does not contain specific per diem rates because
travel is infrequent; therefore it does not serve as an adequate guide
for developing a policy. HUD's regulations require that the policy be
comparable to local public practice not housing industry norms.

Recommendation

We recommend that the Grand Rapids Office's Director of Public Housing
require the Benton Township Housing Commission to:

2A. Revise its travel policy so that it is comparable with the City of
  Benton Harbor.

Finding 3

The Commission Charged Excessive Payroll Costs To The Comprehensive
Improvement Assistance Program

The Benton Township Housing Commission charged excessive payroll costs to
the Comprehensive Improvement Assistance (modernization) Program.
Modernization funds that were available at year end were inappropriately
divided between the payroll costs of three employees. The Commission
charged $67,479 to the Program. The employees' time records supported
that costs of only $11,409 should have been charged to the Comprehensive
Improvement Assistance Program. As a result, $56,070 of modernization
funds were not available or used for the intended purposes of making
physical and management improvements at the Commission. Instead, the
Commission used the funds to inappropriately subsidize its low-income
housing operations.

HUD Requirements

HUD Regulation 24 CFR 85.20 requires the Housing Commission to maintain
records that adequately identify the source and application of funds
provided for Federally assisted activities. The Commission must assure
that the funds are used only for authorized purposes. Section 85.22(b)
requires the Commission to comply with the Office of Management and
Budget Circular A-87-HB 1300.18. The Circular requires that salaries and
fringe benefits chargeable to more than one program must be supported by
appropriate time distribution records.

Regulation 24 CFR 968.205 (e) requires that all prorations of salaries
must be justified by the Housing Commission.

Records Did Not Support Allocation of Salaries

The Benton Township Housing Commission charged $56,070 in excessive
payroll costs to the Comprehensive Improvement Assistance (modernization)
Program. The Commission did not follow HUD's requirements. The
Commission charged the modernization program for salaries and benefits
that were not applicable to the modernization program. For fiscal year
1994, the Commission charged $67,479 to the modernization program for
three employees. The employees time distribution records, however,
supported charges of only $11,409 for time spent working on the
Comprehensive Improvement Assistance Program.

The Executive Director said the fee accountant divided all unspent
comprehensive program funds at the 1994 year end between the three
employees' payroll costs. The fee accountant said she was unaware that
she should have prorated the salaries and benefits costs based on the
actual time spent by each employee on the modernization program.

As a result, modernization funds of $56,070 were not available or used
for the intended purpose: to make management and physical improvements
at the Commission. Additionally, since the funds should have been
charged to the low-income housing program and were not, HUD could not
accurately assess the Commission's performance for the low-income housing
program.

Auditee Comments

The Benton Township Housing Commission takes issue with the statement
that excessive payroll costs were charged to the Comprehensive
Improvement Assistance Program. It was stated that the Commission
inappropriately divided modernization funds that were available at year
end between the payroll costs of three employees. Contrary to the above
statement, the fee accountant distributed funds that were approved by HUD
in the 1410 Administration account of three on-going programs. The
approved amount of $107,018 was to be distributed according to the
budget.

A search for a person to be modernization coordinator was not productive.
The Maintenance Supervisor, the Procurement Specialist and the Executive
Director, therefore, performed the modernization coordinator duties and
the administrative functions of the position remained with the three. At
the end of the year, the fee accountant charged off salaries and benefits
according to the HUD approved percentages.

It is the opinion of the Commission that the charges for the three
employees were appropriate. The funds were never approved in the 1408
accounts to make management and physical improvements, but were approved
to be used in the 1410 administrative account.

Not hiring the Coordinator and distributing the duties to the three
employees resulted in a cost savings of $39,539 that was available to be
re-directed to other purposes.

OIG Evaluation of Auditee Comments
The fact that HUD approved the budget does not mean the Commission can
charge the applicable accounts if there is no support that costs charged
were actually incurred. The finding showed that the Commission charged
the Comprehensive Improvement Assistance Program for costs that it could
not support. For the $67,479 charged to the program, only $11,409 was
supported by time distribution records. The Commission did not provide
any documentation to support the charges of $56,070. Since the funds were
intended to be used to hire a Coordinator, it does not appear that not
hiring one resulted in a cost savings. The Coordinator's duties
performed by Commission personnel took time away from the performance of
their regular duties which included addressing the other problems we
found.

Recommendations

We recommend that the Grand Rapids Office's Director of Public Housing
assures the Benton Township Housing Commission:

3A. Reallocates $56,070 from the Comprehensive Improvement Assistance
  Program to the low-income housing program.

3B. Establishes procedures and controls to assure that the Programs
  administered by the Commission, like the Comprehensive Improvement
  Assistance Program or other modernization programs, are only charged
  for the actual time spent by each employee.

Internal Controls

In planning and performing our audit, we considered the internal controls
of the management of the Benton Township Housing Commission in order to
determine our auditing procedures and not to provide assurance on
internal controls. Internal controls consist of the plan of organization
and methods and procedures adopted by management to ensure that resource
use is consistent with laws, regulations, and policies; that resources
are safeguarded against waste, loss, and misuse; and that reliable data
are obtained, maintained, and fairly disclosed in reports.

Relevant Internal Controls

We determined that the following internal controls were relevant to our
audit objectives:

-- Management Policies, Procedures, and Practices

-- Management monitoring methods
-- Documentation

-- The correctness of reports submitted to HUD

We assessed all the relevant controls identified above.

It is a significant weakness if internal controls do not give reasonable
assurance that resource use is consistent with laws, regulations, and
policies; that resources are safeguarded against waste, loss, and misuse;
and that reliable data are obtained, maintained, and fairly disclosed in
reports.

Significant Weaknesses

Based on our audit, the followings items are significant weaknesses:

-- Management Policies, Procedures, and Practices. The Housing
   Commission did not follow adequate policies, procedures, and
   practices to assure: vacant units were prepared and leased in a
   timely manner (see Finding 1); its travel policy was comparable to
   local practice (see Finding 2); and payroll costs were charged to
   the modernization program based on the actual time spent by each
   employee (see Finding 3).

Follow Up On Prior Audits

This is the first Office of Inspector General audit of the Benton
Township Housing Commission. The Commission's last Independent
Accountant's audit report was for the year ended September 30, 1994. It
did not contain any findings.

Appendix A

Auditee Comments

[Available in official printed copy ONLY.]

.