oversight

Buffalo Municipal HA, Buffalo, NY

Published by the Department of Housing and Urban Development, Office of Inspector General on 1996-06-21.

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

                                                                   Issue Date

                                                                        June 21, 1996
                                                                   Audit Case Number

                                                                        96-NY-201-1002




TO:           Harry A. Reese, Director, Office of Public Housing
                         Buffalo Area Office


FROM:         A. Paul Kane, District Inspector General for Audit
                       New York/New Jersey


SUBJECT:      Buffalo Municipal Housing Authority
              Low-Rent Housing Programs
              Buffalo, New York


We conducted an audit of the Buffalo Municipal Housing Authority of the City of Buffalo, New
York (hereafter referred to as the BMHA) pertaining to its Low-Rent Housing programs. The
purpose of the audit was to determine whether the BMHA is:

   •   providing tenants with decent, safe and sanitary units that meet mandatory minimum
       Housing Quality Standards (HQS) prescribed by the U.S. Department of Housing and
       Urban Development (HUD);

   •   complying with the terms and conditions of its Annual Contributions Contract (ACC),
       applicable laws, HUD regulations, and other applicable directives; and

   •   managing its programs and operations effectively, efficiently, and economically.

Our audit disclosed that the BMHA is generally providing tenants with decent, safe and sanitary
units; and is generally complying with the terms and conditions of its ACC. However, the review
also disclosed that various improvements are needed in its operations to enhance effectiveness,
increase efficiency, and promote better economy. Specifically, our audit results disclosed that
the BMHA should improve its: management information systems, maintenance operations,
controls over inventories, unit vacancy rate, cash management procedures and investment
practices, controls over staffing levels, travel and personnel practices, and the system used to
process purchase orders. Also, the BMHA should improve the accuracy of its Public Housing
Management Assessment Program (PHMAP) Certification, and execute an employment contract
with each employee appointed by the Board of Commissioners to reduce the possibility of
litigation if termination occurs.

Within 60 days, please give us for each recommendation made in the report, a status report on:
Management Memorandum



(1) the corrective action taken; (2) the proposed corrective action and the date to be completed;
or (3) why action is not considered necessary. Also, please furnish us copies of any
correspondence or directives issued related to the audit.

Should you or your staff have any questions, please contact Alexander C. Malloy, Assistant
District Inspector General for Audit at (212) 264-8000, extension 3976.




96-NY-201-1002                                Page ii
Executive Summary
We conducted an audit of the Buffalo Municipal Housing Authority (herein referred to as the
BMHA) pertaining to its Low-Rent Housing programs. The objective of the audit was to
determine whether the BMHA is:

   •   providing tenants with decent, safe and sanitary units that meet HUD's mandatory
       minimum HQS;

   •   complying with the terms and conditions of its Annual Contributions Contract (ACC),
       applicable laws, HUD regulations, and other applicable directives; and

   •   managing its programs and operations effectively, efficiently, and economically.

Our review disclosed that the BMHA is generally providing tenants with decent, safe, and
sanitary units; and is generally complying with the conditions of its ACC, applicable laws, HUD
regulations, and other directives. However, the audit also disclosed that improvements are
needed in the BMHA's operations to enhance effectiveness, increase efficiency, and promote
better economy. In order to accomplish this, the BMHA needs to take the necessary actions to
correct the deficiencies noted during our audit, which are summarized below and described in the
findings of this report.




                                    The BMHA's management information systems do not
  BMHA's management                 provided accurate, reliable and timely information. We
  information systems do            attribute this weakness to the lack of a centralized computer
  not provide accurate,             system, as well as, the absence of adequate expertise to
  reliable and timely               properly manage its current information systems. As a
  information                       result, BMHA employees, including top management, do
                                    not have accurate and current information readily available
                                    to assist in making sound decision on how and where scarce
                                    resources are to be used.

                                    The BMHA's maintenance operations lack: (a) a reliable
 BMHA's maintenance
                                    and effective maintenance information system; (b)
 structure does not
                                    maintenance performance standards for its maintenance
 adequately provide for
                                    employees; and (c) adequate management oversight. As a
 proper staff account-
                                    result, the current maintenance structure does not
 ability and productivity
                                    adequately provide for proper staff accountability and
                                    productivity.




                                             Page iii                                95-NY-201-1002
Executive Summary



                           The BMHA's controls over inventories are not adequate
 BMHA's controls over
                           enough to properly safeguard its materials, supplies, and
 inventories are not
                           equipment. We found that inventory records were not
 adequate
                           accurate and that inventory policies were not applied
                           consistently or in compliance with HUD guidelines. Also,
                           we noted that items were missing, stolen, and/or used for
                           unauthorized purposes and that the supply inventory was
                           not valued consistent with HUD guidelines. As a
                           consequence, the BMHA does not have adequate assurance
                           that items in its inventories are properly accounted for and
                           correctly valued; or that adequate internal controls are in
                           place to promptly detect theft or misuse. We attribute these
                           weaknesses to a lack of: (a) managerial oversight, (b) an
                           authority-wide inventory policy, and (c) a reliable inventory
                           costing system.

                           The BMHA's unit vacancy rate has consistently exceeded
 BMHA's unit vacancy
                           20 percent. The high rate is attributable to the BMHA's
 rate has consistently
                           failure to perform unit turnaround activities timely, which
 exceeded 20 percent
                           includes: (a) offering vacant units to applicants, (b)
                           preparing vacant units for reoccupancy, and (c) executing
                           leases with prospective tenants. Additionally, we believe
                           that the number of units designated for the elderly or
                           disabled may be greater than the actual need; and is
                           therefore having a negative impact on the BMHA's vacancy
                           rate. As a result, the housing needs of certain low-income
                           applicants are not being met promptly.

                           The BMHA's controls over cash management practices are
 BMHA did not invest its
                           not adequate. Specifically, we noted that the BMHA did
 excess funds
                           not invest its excess funds; failed to periodically solicit or
                           evaluate its banking services; and improperly advanced
                           operating funds of Federal programs to pay costs incurred
                           under non-Federal programs. As a result, no investment
                           income was earned, banking services may not be adequate,
                           and Federal funds were improperly advanced to pay costs
                           incurred under non-Federal programs. We believe that
                           these conditions occurred because the BMHA procedures
                           in the areas of investing, banking, and requesting funds
                           from the City of Buffalo were not adequate.

 BMHA's staff levels       The BMHA's staffing levels exceed HUD's suggested
 exceed HUD's suggested    levels; some of its staff is not being adequately utilized; and
 levels                    its controls over overtime and travel are not adequate.


95-NY-201-1002                      Page iv
                                                                          Executive Summary



  Additionally, the BMHA's Commissioners are receiving compensation in breach of the ACC.
  We attributed these deficiencies to management's failure to evaluate staffing levels, the lack
  of a formal written personnel policy, inadequate controls over certain aspects of travel and
  overtime, and insufficient oversight by management. As a result, the BMHA cannot assure
  HUD that all staffing, overtime, and travel costs are necessary and reasonable to the
  operations of the projects. Regarding the unauthorized payments of compensation to the
  Commissioners, this resulted in ineligible expenses of $32,825.

                                   The BMHA's current purchase order system is cumbersome
BMHA's purchase order
                                   and time consuming. As a result, more staff time than
system is cumbersome
                                   should be required is used to process purchase orders. This
and time consuming
                                   deficiency occurred because the BMHA does not have a
                                   uniform purchase order system in place to process purchase
                                   orders timely.

                                   The BMHA's Public Housing Management Assessment
BMHA's PHMAP
                                   Program (PHMAP) Certification; as submitted to HUD, for
Certification contain
                                   Fiscal Year Ending June 30, 1994, contains various
conclusions that were
                                   conclusions that were based on inaccurate information and
based on inaccurate
                                   data. The erroneous conclusions resulted from incorrect
information and data
                                   calculations of some indicators; the use of improper
                                   procedures in computing the scores of indicators; and the
                                   BMHA's failure to assure that computer generated data was
                                   accurate.

                                   The BMHA charged the entire cost associated with
BMHA charged the
                                   settlement payments to terminated employees, whose
Federal program the
                                   responsibilities included oversight duties over all BMHA
entire amount paid to
                                   programs, to the Federal program. It is the BMHA's
terminated employees
                                   position that the settlement payments were made to avoid
                                   litigation, which we attribute to the lack of employment
                                   contracts containing termination terms. Consequently, the
                                   BMHA incurred and charged a total of $92,214 to the
                                   Federal program in connection with the termination of three
                                   employees. Since the employees duties also included
                                   management oversight over State funded programs, we
                                   believe that the $92,214 should have been allocated among
                                   all programs administered by the BMHA.

                                   As part of each finding, we recommended certain
Recommendations
                                   improvements that will assist in eliminating the deficiencies
                                   discussed in the finding and will strengthen BMHA's
                                   administration of its Low-Rent Housing programs.



                                            Page v                                  95-NY-201-1002
Executive Summary



                    The results of the audit were discussed with BMHA
 Exit Conference
                    officials during the course of the audit and at an exit
                    conference held on April 9, 1996, attended by:

                    Buffalo Municipal Housing Authority

                    Sharon West, Executive Director
                    Modesto Candelario, Chairperson,
                               Board of Commissioners
                    James F. Lagona, Assistant Legal Counsel

                    Buffalo Area Office - Office of Public Housing (OPH)

                    Harry Reese, Director, OPH
                    Joan Spilman, Director, Management, OPH
                    John E. Lollis, Director, Financial Management, OPH
                    Ken O'Connor, Engineer, OPH
                    Joe Raimond, Engineer, OPH
                    Ron Cianciosi, Financial Analyst, OPH

                    Office of Inspector General (OIG)

                    Alexander C. Malloy, Assistant District
                             Inspector General for Audit
                    Garry D. Clugston, Senior Auditor
                    Theresa Semanek, Auditor
                    Patrick Anthony, Auditor

                    The BMHA agreed with some of the deficiencies mentioned
                    in the findings and disagreed with others. We summarized
                    the BMHA's response, and provided appropriate portions of
                    our summarization after each finding. Where appropriate,
                    we have prepared an evaluation of the BMHA's comments.




95-NY-201-1002              Page vi
Table of Contents

Management Memorandum                                               i


Executive Summary                                                  iii


Introduction                                                        1


Findings

    1      The BMHA Needs a Reliable Comprehensive
           Management Information System                            3

    2      The BMHA Needs to Ensure That Its Maintenance
           Operations are Efficient and Economical                  7

    3      The Controls Over Inventories Need
           Strengthening                                          15

    4      The BMHA's Unit Vacancy Rate Needs to
           be Reduced                                             25

    5      The BMHA Needs to Improve Cash
           Management Procedures                                  35

    6      The BMHA Needs to Improve Personnel
           Practices                                              39

    7      The BMHA Needs to Implement a Uniform
           System to Process Purchase Orders                      47

    8      The Accuracy of the PHMAP Certification is


                             Page vii                   96-NY-201-1002
Table of Contents




                 Questionable                                          51

        9        Settlement Cost Should Have Been Allocated
                 Among all Programs                                    57


Other Matters                                                          61


Internal Controls                                                      63


Follow Up On Prior Audits                                              65


Appendices

        A        Distribution                                          67


Abbreviations
        ACC         Annual Contributions Contract
        AIT         Advanced Integrated Technology
        BMHA        Buffalo Municipal Housing Authority
        HUD         U.S. Department of Housing and Urban Development
        HQS         Housing Quality Standards
        MCS         Maintenance Costing System
        MIS         Management Information System
        MOA         Memorandum of Agreement
        OIG         Office of Inspector General
        OPH         Office of Public Housing
        PHMAP       Public Housing Management Assessment Program
        RFP         Request for Proposal
        VAPC        Vacant Apartment Preparation Crew




96-NY-201-1002                             Page viii
Introduction
The Buffalo Municipal Housing Authority (BMHA) was established in 1934 to provide decent,
safe and sanity housing for eligible low and moderate income families in the City of Buffalo.
The BMHA administers 25 federally funded projects, with 5,042 public housing units and 2
active state funded projects, containing 973 units .




                                   The BMHA is governed by a Board of Commissioners (the
 Governing body
                                   Board) composed of seven members; five are appointed by
                                   the Mayor and two are elected by the tenant population.
                                   The Chairperson of the Board is Modesto Candelario. At
                                   the start of our audit the Executive Director of the BMHA
                                   was Michael Clarke. On July 31, 1995, Sharon West was
                                   appointed Executive Director by the Board. The Executive
                                   Director, whose office is located at 300 Perry Street,
                                   Buffalo, New York , is responsible for the day to day
                                   operations of the BMHA. The BMHA's financial records
                                   and books are maintained primarily at its central office
                                   located at 300 Perry Street.

                                   For the Fiscal Year Ended June 30, 1991, the BMHA's
 A MOA between HUD
                                   PHMAP scores was 48.8 percent, resulting in the BMHA
 and the BMHA was
                                   being designated a troubled public housing authority by
 executed
                                   HUD. Because of the low PHMAP score, a Memorandum
                                   of Agreement (MOA) between HUD and the BMHA was
                                   executed in July, 1992, which resulted in the establishment
                                   of baseline data in key performance areas and annual
                                   performance standards. After the completion of the MOA,
                                   in March 1993, the BMHA submitted an Improvement
                                   Plan to HUD in response to its June 1992 PHMAP
                                   evaluation. The Improvement Plan contained tasks and
                                   performance targets for the PHMAP indicators with scores
                                   below a grade C. The BMHA's PHMAP score increased
                                   from 48 percent in 1991 to 70 percent in 1994, which was
                                   high enough for HUD to remove the BMHA from its list of
                                   troubled public housing authorities.

                                   In April 1989, HUD found that the BMHA's tenant
 Occupancy problems
                                   assignment practices violated regulations of Title VI of the
                                   Civil Rights Act of 1964, as amended. On December 4,
                                   1989, the BMHA and HUD were name in a lawsuit
                                   concerning the Title VI requirements. In 1992 HUD and


                                            Page 1                                 96-NY-201-1002
Introduction



                       the BMHA signed a Voluntary Compliance Agreement
                       designed to bring the BMHA into compliance with the Title
                       VI regulations. Our review disclosed that the BMHA is
                       generally complying with terms of the agreement.

                       The BMHA received operating subsidies during our audit
 Operating subsidies
                       period from HUD, as follows:
 received from HUD

                               Fiscal Year          HUD Operating Subsidies
                                   1993                    $12,942,801
                                   1994                     13,626,480

                       The primary objectives of the audit were to determine
 Audit Objectives
                       whether the BMHA is:

                       •   providing tenants with decent, safe and sanitary units
                           that meet HUD's mandatory minimum HQS;

                       •   complying with terms and conditions of its ACC,
                           applicable laws, HUD regulations and other applicable
                           directives that were in effect during our audit period;
                           and

                       •   managing its programs and operations effectively,
                           efficiently, and economically.

                       Our audit field work was performed between January 1995
 Audit Period
                       and September 1995 and covered the period from July 1,
                       1993 to December 31, 1994. However, activity prior and
                       subsequent to this period was reviewed when appropriate.

                       Audit procedures included an examination of the books,
 Scope
                       records and files of the BMHA, files maintained by HUD,
                       interviews with members of the BMHA and HUD staffs,
                       and project site visits. Furthermore, we reviewed, the
                       BMHA's organizational structure, polices, and procedures
                       for managing its operations. Performed detailed audit
                       testing, which was based primarily on judgementally
                       selected samples of the transactions in the areas reviewed.

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


96-NY-201-1002                  Page 2
                                           Introduction



A copy of this audit report was provided to the BMHA.




        Page 3                              96-NY-201-1002
                                                                                        Finding 1




 The BMHA Needs a Reliable Comprehensive
      Management Information System


The BMHA's management information systems is fragmented among various departments and
is not providing top management with current and accurate information to assist in making sound
decisions on how and where scarce resources should be used. As a result, we found that the
BMHA is unable to: (a) measure the productivity levels of its staff in a timely manner; (b) readily
determine whether its various components are operating in a efficient and economical manner;
or (c) properly safeguard and protect resources, such as equipment, material and supplies from
theft or improper use. We attribute this deficiency to the absence of a reliable centralized
management information system that consolidates departmental information into a form usable
by employees and management for operational as well as decision making purposes.




                                      The Annual Contributions Contract (ACC) requires PHAs
 Criteria
                                      to adopt necessary procedures to ensure that operations are
                                      run economically and efficiently. In order to accomplish
                                      this, PHAs should have a efficient management information
                                      system to record, track and consolidate data in a form
                                      usable by management.

                                      Our review of the PHA's management information systems
 Scope
                                      was an ongoing process during the audit. The review
                                      included examinations and observations of the systems used
                                      by the BMHA to record financial transactions, track work
                                      orders, work performed by the maintenance staff,
                                      nonexpendable equipment, and inventories of materials and
                                      supplies.

                                      Our review disclosed that the BMHA does not have a
 The BMHA does not
                                      reliable centralized computer system. Instead, each
 have a reliable computer
                                      department developed its own computerized system, which
 system
                                      in most cases, are not being adequately maintained. For
                                      example, the maintenance work order database system
                                      contains a substantial amount of inaccurate, unreliable, and
                                      unnecessary data. Also, the system lacks adequate security,
                                      and in many cases can not produce information in a form



                                               Page 3                                  96-NY-201-1002
Finding 1



                          usable by employees and top management (See Finding 2).
                          Furthermore, we found that inventory records are
                          maintained on several different computer systems, and have
                          not been reconciled. The data contains errors,
                          misclassifications, and improper cost valuations. Moreover,
                          the systems are not capable of providing a total inventory
                          listing or usage reports. (Finding 3).

                          Regarding the BMHA's computerized accounting system,
 BMHA is using computer
                          we found that the system listed charges from prior years to
 programs that are
                          purchasing contract accounts when no charges had been put
 outdated and very time
                          into the systems. Also, we noted that accounting functions,
 consuming
                          such as payroll require information to be manually
                          transferred from one computer system to another. To
                          accomplish the transfers, some accounting staff members
                          have two different computer work stations on their desk.
                          Overall, our review disclosed that the BMHA is using
                          computer programs that are outdated and very time
                          consuming; and that many staff members lack adequate
                          expertise in computer operations and programming.

                          In our opinion, the lack of a reliable comprehensive
 BMHA needs to
                          management information system precluded top
 implement a reliable
                          management officials from having accurate, complete, and
 comprehensive
                          timely data on the BMHA's various operations, especially
 management information
                          its maintenance and related components. Consequently, the
 system
                          BMHA lacks evidential assurance that its personnel was
                          effectively and fully utilized; that its equipment, materials
                          and supplies were adequately protected and properly used;
                          and that its activities were carried out in an effective,
                          efficient and economical manner. In this regard, the
                          BMHA needs to implement a reliable comprehensive
                          management information system and ensure that its staff
                          has the ability to manage and use the system.



Auditee Comments          The BMHA response provides that the BMHA is utilizing
                          a Data General and AS400 hardware system. The software
                          system is Advanced Integrated Technology (AIT). The
                          current computer system is insufficient to manage and
                          monitor the comprehensive operation of the Authority and
                          has caused tremendous difficulties in operating the
                          programs in several departments of the BMHA.



96-NY-201-1002                     Page 4
                                                                     Finding 1



                  In December, 1995, as part of the BMHA reorganization, a
                  Management Information System (MIS) Division was
                  established with a new MIS Director and Computer
                  Programmer positions. Top management of the BMHA
                  believes that the addition of these positions will have direct
                  and immediate impact upon the capacity of the Authority to
                  address many of the problems found with the current
                  computer system. Moreover, BMHA officials will evaluate
                  and install new software to assist in overcoming current
                  problems. BMHA officials are currently working with the
                  Buffalo Civil Service Commission to fill these positions. It
                  is the BMHA's goal to solve the MIS problems within the
                  next two years.

                  The BMHA will enter into a contract in May 1996 with Erie
                  Community College to train its personnel on effective PC
                  use in a Windows environment.

                  Moreover, once the MIS Director and computer
                  programmer are on board, the BMHA will develop the in-
                  house capacity to train on the AIT and other software.



Recommendations   We recommend that your office ensure that the BMHA:

                  1A.    Perform a full evaluation of its computer hardware,
                         software, and programming needs; and implement
                         a comprehensive management information system
                         that meets the needs of the BMHA.

                  1B.    Evaluate and train personnel to ensure that they
                         have the necessary skills to use and maintain a
                         reliable management information system.




                           Page 5                                  96-NY-201-1002
Finding 1




                 (THIS PAGE LEFT BLANK INTENTIONALLY)




96-NY-201-1002                   Page 6
                                                                                       Finding 2




      The BMHA Needs to Ensure That Its
     Maintenance Operations are Efficient and
                  Economical
The maintenance operations at the BMHA are not being carried out in a manner that adequately
promotes efficiency and economy. This is occurring because the BMHA's maintenance
operations lack: (a) a reliable and effective maintenance information system that accounts for
work performed by the maintenance staff; (b) performance standards and productivity levels for
its maintenance employees; and (c) adequate management oversight. Consequently, we found
strong indications which show that staff resources are not properly accounted for nor fully
utilized.



                                    The National Housing Act of 1937, as amended, requires
 Criteria
                                    each authority to establish sound management practices in
                                    the operations of its projects, including the formulation and
                                    implementation of satisfactory project maintenance
                                    standards. In addition, Section 201 of the ACC requires
                                    that the local authority at all times operate each project for
                                    the purpose of providing safe and sanitary dwellings in such
                                    a manner as to promote efficiency and economy.


                                    a) Maintenance information system is not reliable
 The Accuracy and
                                    To evaluate the reliability of BMHA's maintenance
 reliability of the work
                                    information system, we obtained data for the two week
 order database is
                                    period ended July 30, 1994, which consisted of 11,179
 questionable
                                    work order records. Those records disclosed significant
                                    problems with the BMHA's computerized work order
                                    system. First, from the sample of 11,179 records, we
                                    determined that 7,002 of the records reflected either
                                    employee numbers that do not exist or data unrelated to
                                    work performed by the maintenance staff. Also, the system
                                    generated information concerning time and cost that was
                                    not consistent with the data on individual work order
                                    records. BMHA maintenance personnel were unable to
                                    explain how the information got into the system or why the
                                    data did not agree with the individual records. Thus, the



                                             Page 7                                  96-NY-201-1002
Finding 2



                            accuracy and reliability of the work order database is
                            questionable.

                            We were informed that the work order database system
 Inquiries are very
                            generated more than 500,000 records in just over two years
 difficult and time
                            of operation. The large number of records can be partly
 consuming
                            attributed to records that do not represent actual work
                            performed. Moreover, we found that a lot of the records
                            pertain to work orders that were not related to maintenance
                            assignments. They included work orders for material
                            ordered for the inventory, inspections, and maintenance of
                            the general grounds. Since the system has to examine all
                            available records to find requested data, it is difficult and
                            very time consuming to perform inquiries.

                            b) Maintenance performance standards and productivity
                               levels have not been established

                            The BMHA lacks performance standards to measure the
 No uniform method to
                            performance of its maintenance staff. These standards
 monitor and evaluate
                            would consist of a description of the various maintenance
 maintenance staff
                            and repair items performed by the maintenance staff with
 productivity
                            expected completion times. Additionally, the BMHA does
                            not have an adequate process to measure the productivity
                            levels of its maintenance staff. As a result, the BMHA does
                            not have adequate assurance that its maintenance staff is
                            productive and its maintenance operating costs are
                            economical.


                            As discussed in Finding 6, the BMHA exceeds the guidance
 Maintenance staff
                            provided by HUD of one maintenance employee for every
 exceeds national average
                            forty units. Currently, the BMHA has one maintenance
                            employee for every twenty-two available units. Using
                            HUD's staffing guidelines, we determined that the BMHA
                            has 103 more maintenance employees than suggested by
                            HUD guidelines. To evaluate the efficiency of the BMHA's
                            maintenance staff, we judgmentally selected and analyzed
                            various completed work orders.

                            First, we selected the months of July 1994 and March 1995
 Average work orders
                            to determine the average number of work orders completed
 completed daily ranged
                            daily. We focussed on the mechanics, laborers, and
 from .95 to 7.17
                            tradesmen in Technical Operations since they performed


96-NY-201-1002                       Page 8
                                                                                  Finding 2



  most of the maintenance work tracked by work orders. From available data, we determined
  that the average number of work orders completed daily for the selected two months ranged
  from .95 for plasterers to 7.17 for the mechanics/laborers. The following table shows the
  average number of work orders completed daily by job classification during the two months
  selected:


                                                                       Average
                                        Job Classification             Numbers of
                                            by Group                   Work Orders
                                                                       Completed
                                                                       Daily
                                    PLASTERERS                                  0.95
                                    PAINTERS                                    1.82
                                    CARPENTERS                                  1.93
                                    NIGHT SHIFT                                 2.09
                                    PLUMBERS                                    2.55
                                    ELECTRICIANS                                2.62
                                    EXTERMINATORS                               3.14
                                    GLAZIERS                                    3.14
                                    PMI CREW                                    3.51
                                    MECHANICS/LABORER                           4.28
                                    S - LAKEVIEW
                                    MECHANICS/LABORER                           5.65
                                    S - SHAFFER VILLAGE
                                    MECHANICS/LABORER                           6.03
                                    S -COMMODORE
                                    PERRY
                                    MECHANICS/LABORER                           7.17
                                    S -KENFIELD


                                 Second, we determined the amount of hours charged on
Only 3 of the job
                                 completed work orders for each group for the period from
classifications had 50
                                 July 17, 1994, through July 30, 1994 and classified that
percent or more of its
                                 time as productive time. The time that was not accounted
time charged to work
                                 for on a work order was classified as unproductive. In this
orders
                                 regard, we determined each group's percentage of
                                 productive time by taking the amount of hours charged on


                                          Page 9                                96-NY-201-1002
Finding 2



                 completed work orders and dividing them by total hours
                 worked during the period. As such, we determined that
                 only 3 of the 13 groups had 50 percent or more of their time
                 charged on work orders. The following graph shows the
                 amount of productive time for each group:




                 Additionally, we combined the amount of productive time
                 for all groups. For the sample period, 3,728 hours were
                 charged as worked; however, only 1,551 hours were
                 reflected on work orders. Thus, 2,177 hours representing
                 over 58 percent of the maintenance hours worked can not
                 be accounted for and is being classified as unproductive
                 time. The following graph compares the productive time to
                 the unproductive time:




96-NY-201-1002           Page 10
                                                                           Finding 2




                          The low number of completed work orders and the
BMHA needs to develop
                          amount of unproductive time indicates that the BMHA's
performance and
                          maintenance operation is not efficient. The BMHA needs
productivity standards
                          to account for the total time each maintenance employee
                          is on duty. In doing so, the BMHA should develop and
                          implement performance standards for common work tasks
                          and routine repairs. This will allow the BMHA to: 1)
                          account for the on duty hours of each maintenance staff,
                          and 2)      evaluate the productivity of individual
                          maintenance employees. Furthermore, performance
                          standards will provide the maintenance staff with the
                          measurable level of productivity expected of them.

                         c) Management oversight is inadequate

                         The lack of a reliable and effective maintenance
BMHA's management
                         information system, which would include performance
oversight is weak
                         standards and productivity levels for its maintenance staff,
                         has significantly weakened the BMHA's ability to
                         adequately perform oversight duties and evaluations of its
                         maintenance operations.           Without such a system,
                         management is unable to determine and document whether
                         its maintenance staff is productive or whether its
                         maintenance functions are being performed in an efficient


                                 Page 11                                 96-NY-201-1002
Finding 2



                   and economical manner. To accomplish this, we believe
                   that management may need to obtain consultant services to
                   assist in:    (1) implementing a reliable maintenance
                   information system;         (2) determining whether its
                   maintenance functions are being performed in an efficient
                   and economical manner; and (3) evaluating staffing
                   needs and determining whether it would be more cost
                   beneficial to privatize some of the maintenance functions.




Auditee Comments   The BMHA's response states "We are aware of many of the
                   problems that the reviewer indicated. At the time of the
                   review, it was explained, that this was the first full year on
                   the system. Many problems occurred in: 1. training the
                   staff, and 2. getting the staff to accept and work with the
                   system because of the many human errors that occurred.
                   There are also problems in locking out staff so that they
                   could only view and not change anything in the system.
                   Now only supervisors have this ability. Many of the
                   problems that were indicated were part of our $100,000
                   contract with AIT which was entered into on September 30,
                   1994. Since that time the company went out of business
                   leaving us without corrections to our problems. Since then
                   SSC, a consortium of Housing Authorities using the same
                   system has been formed in a attempt to rectify the
                   problems. We have also made arrangements with Ms. Judy
                   Lewis of the Syracuse Housing Authority, who was one of
                   the original developers of the system, who will visit the
                   BMHA in April 1996 to assist us in solving our computer
                   problems."

                   The BMHA's response also provides that the main issue in
                   this finding is that the BMHA does not have established
                   Performance Standards and Productivity levels.
                   Management of the BMHA agrees with the reviewer on this
                   issue. In order to establish these standards and levels, the
                   BMHA has allocated monies in the 96 CGP for outside
                   assistance by 12/97 in establishing these performance
                   standards and productivity levels.        Once these are
                   established, the BMHA will be able to determine if staffing
                   should remain the same, be reallocated and/or reduced. The
                   results of this could also supply the BMHA with a basis for
                   making any decisions concerning privatization. Any work


96-NY-201-1002             Page 12
                                                                      Finding 2



                  done on establishing standards, levels or privatization will
                  have to be fully discussed and receive support from the
                  Unions.



Recommendations   We recommend that your office ensure that the BMHA:

                  2A.       Take steps to evaluate and correct the current
                            computerized maintenance information system, so
                            that:
                        •   The system can be relied upon to provide accurate
                            and reliable information.
                        •   Data can be extracted timely from the system to aide
                            in management decisions.
                        •   Obtain adequate technical assistance for the system
                            either in house or from outside consultants.

                  2B.       Establish performance standards for maintenance
                            tasks so that the maintenance staff is knowledgeable
                            of the productivity levels that are expected of them
                            by management.

                  2C.       Evaluate, after performance standards, are in place,
                            the productivity of the maintenance staff to
                            determine whether staffing needs to remain the
                            same, be reallocated and/or reduced.

                  2D.       Determine whether any maintenance functions
                            should be privatized.




                             Page 13                                96-NY-201-1002
Finding 2




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96-NY-201-1002                   Page 14
                                                                                       Finding 3




           The Controls Over Inventories Need
                     Strengthening

Our review disclosed that the BMHA's inventory controls are not adequate enough to properly
account for and safeguard its inventory of equipment, materials and supplies. Specifically, our
review of nonexpendable equipment inventories disclosed that: a) inventory records are not
maintained properly; b) capitalization and other inventory policies are not in compliance with
HUD guidelines; c) stolen or missing equipment was not written off properly; and d) equipment
belonging to the Federal program is being used at a State project. Regarding the inventory of
materials and supplies, our review disclosed that: a) the inventory level is excessive; b)
reconciliations of differences between the physical inventory and accounting records are not done
properly; and c) items in the inventory were not valued in accordance with HUD guidelines. As
a result, the BMHA does not have adequate assurance that inventories are accurate, accounted
for and properly valued; that inventory levels of materials and supplies on-hand are necessary;
and that internal controls are adequate to promptly detect theft and misuse. We attribute these
weaknesses to the BMHA's lack of adequate controls over inventories and managerial oversight;
to inconsistent authority-wide policies; and to a lack of a reliable inventory costing system.
Specific weaknesses in the BMHA's inventory system are discussed in the following subsections:




                                     (1) NONEXPENDABLE EQUIPMENT INVENTORY

                                     a.     Inventory records are not properly maintained

                                     The BMHA's inventory records are not maintained in
 Inventory records are not
                                     accordance with HUD requirements. HUD Handbook
 maintained in compliance
                                     7510.1, Chapter 7 provides that PHAs shall establish and
 with HUD requirements
                                     maintain complete and accurate records of all real and
                                     personal property. Our audit testing disclosed that:
                                     equipment purchases were not properly recorded;
                                     capitalization of equipment was not done in accordance
                                     with HUD requirements; inventory records did not contain
                                     sufficient documentation for equipment identification; asset
                                     identification numbers were not listed on equipment or the
                                     inventory records; and the equipment location, as stated on
                                     the inventory card did not correspond with the actual
                                     location of the equipment. As a result, we could not verify
                                     the existence of various pieces of equipment. We attribute



                                             Page 15                                 96-NY-201-1002
Finding 3



                              these problems to record keeping weaknesses in the
                              BMHA's current inventory system.

                              Additionally, we found that inventories in the various
 Inventories are not
                              departments of the BMHA are not consistently tracked.
 consistently tracked
                              Specifically, we noted that the Accounting Department
                              maintains the authority-wide or master inventory records,
                              which tracks equipment by budget authority. However,
                              each department tracks its own inventory by either office,
                              location, or individual item. Consequently, it is very
                              difficult, if not impossible, to reconcile the departmental
                              inventory to the BMHA's master inventory.

                              Furthermore, we found approximately $200,000 in
 Items misclassified
                              misclassified items. Items pertaining to the general
                              operation and site improvements were classified as
                              nonexpendable equipment. Examples include: security
                              systems, software contract services, computer data
                              conversion services, security consultant services, carpentry
                              work, door locks, carpeting, and window blinds. Such
                              misclassifications cause the amount of the inventory to be
                              grossly overstated which can be misleading if used to
                              project future inventory needs.

                              b.     Capitalization Policy is not in compliance with HUD
                                     guidelines

                              The BMHA's inventory capitalization policy does not
 Capitalization policy does
                              comply with the HUD guidelines provided in Handbook
 not comply with HUD
                              7510.1, Chapter 7. At a minimum, the PHA is required to
 guidelines
                              classify ranges, refrigerators, motor vehicles, power
                              equipment, office furniture, office equipment and similar
                              items of durable nature as nonexpendable equipment.
                              Nonexpendable equipment is defined as items of equipment
                              having a useful life of more than one year. According to
                              members of the BMHA staff, only equipment with a value
                              greater than $300.00 is considered nonexpendable
                              equipment and is capitalized. All equipment, except for
                              ranges and refrigerators with a value less than $300.00 is
                              considered expendable and is expended when purchased.
                              The BMHA capitalization policy does not consider the
                              useful life of equipment. For example, we found that the
                              BMHA only capitalized one out of two identical gas
                              powered line trimmer costing $297.97 for one and $300.00


96-NY-201-1002                        Page 16
                                                                             Finding 3



                          for the other. Although the equipment was identical, only
                          the line trimmer costing $300.00 was capitalized. A
                          BMHA staff member told us that because the cost of one
                          line trimmer was under $300.00, it was not necessary to
                          capitalize that equipment. To avoid such inconsistencies in
                          its capitalization practice, we believe the BMHA should
                          consider useful life as part of its capitalization policy, as
                          required by HUD guidelines.

                          c.     Department inventories were not performed or
                                 reconciled with the accounting records

                          HUD Handbook 7510.1, Chapter 7, Paragraph (5) requires
Equipment inventory not
                          the PHA to take a physical inventory of all items of
reconciled properly
                          nonexpendable equipment annually. The differences
                          between the physical inventory and the accounting records
                          should be reconciled and all necessary adjustments should
                          be made. Differences or adjustments must be documented,
                          reviewed, evaluated, and approved. According to members
                          of the BMHA staff, each department took an annual
                          physical inventory of nonexpendable equipment. However,
                          the physical inventory records have not been reconciled
                          with the accounting records for our audit period. In
                          addition, the departmental inventory records were not
                          reconciled with the master inventory list. Without proper
                          reconciliations, accounting errors or equipment losses can
                          not be accurately identified. The physical inventory and
                          reconciliations are necessary to determine the cause of
                          inventory losses and reductions, and to provide
                          management with information necessary to reduce future
                          losses or errors.

                          d.     Stolen or missing equipment was not written-off
                                 properly

                          The BMHA has not properly written-off missing and/or
Stolen or missing
                          stolen equipment. For our audit period, the BMHA deleted
equipment was not
                          or wrote-off $1,298,000 worth of nonexpendable
written-off properly
                          equipment, which was approximately 23% of the total
                          equipment inventory of $5,690,000. Regarding the write-
                          off, a member of the BMHA staff told us that the housing
                          authority inventory records had not been updated since
                          1984; therefore, the BMHA decided to purge and remove
                          items that were reported missing, stolen, obsolete, or


                                  Page 17                                  96-NY-201-1002
Finding 3



                            scrapped from its inventory records. Also, the BMHA
                            decided to remove the amount of all items costing less than
                            $300.00. Many of those items were listed as whereabouts
                            unknown, missing, or stolen.

                            The BMHA's disposition policy requires that missing,
                            stolen, or sold inventory be approved by the inventory
                            survey committee and then removed from the inventory
                            ledger and accounting records. This policy is not
                            consistently followed by all departments. Although we
                            found equipment that was reported stolen in 1990, deletion
                            memorandums were never approved by the inventory
                            survey committee. In certain cases, equipment was deleted
                            from the departmental records, but not removed from the
                            property ledgers or the master inventory. Consequently, the
                            departmental records and master inventory are not in
                            agreement.

                            e.     Equipment belonging to the Federal program is
                                   being used at a State project

                            The BMHA has not implemented procedures to control and
 Equipment belonging to
                            monitor the use of all equipment. The results of our audit
 the Federal program is
                            testing disclosed that $39,450 of equipment belonging to
 being used at a State
                            the Federal program was assigned to a New York State
 project
                            project. BMHA staff indicated that equipment is often
                            transferred between projects, on a as needed basis; and if
                            equipment is permanently transferred to a state project, a
                            transfer memorandum is sent to the accounting department
                            so that the state program can be charged for the equipment.
                            However, we found that although the previous mentioned
                            equipment has been assigned to a State project; it is still
                            shown in the Federal program's inventory. In this regard,
                            the BMHA needs to either justify assigning the equipment
                            to the State project or execute a transfer memorandum so
                            that the State project can be charged for using the
                            equipment in accordance with its procedures.

                            (2) INVENTORY OF MATERIALS AND SUPPLIES

 The BMHA has not           According to requirements provided in the ACC, PHAs
 managed its inventory of   must manage and operate their projects with maximum
 materials and supplies     efficiency and economy. Our audit disclosed that the
 effectively                BMHA is not in compliance with this requirement as it


96-NY-201-1002                      Page 18
                                                                                      Finding 3



  relates to properly managing its inventory of materials and supplies. Specifically, the audit
  disclosed that: (a) the inventory level of materials and supplies is excessive; (b) the annual
  physical inventory is not reconciled with the general ledger; and (c) the computerized
  Maintenance Costing System does not properly value the inventory. Deficiencies noted
  during our review are as follows:

                                   a.     Inventory level is excessive.

                                   A review of available records disclosed that during Fiscal
Inventory level is
                                   Year 1993, the BMHA had $1,652,825 of materials and
excessive
                                   supplies in its inventory; but only used materials and
                                   supplies valued at $820,309. The review further disclosed
                                   that the same inventory during FY 1994 was $1,722,339,
                                   while usage was valued at $878,720. Based on this
                                   information, the BMHA maintains enough materials and
                                   supplies in its inventory for two years. We believe that
                                   such an inventory level is excessive and expensive to
                                   maintain; and that the material and supply inventory should
                                   be reduced to a level considered reasonable by the BMHA
                                   and HUD management. BMHA officials attributed the
                                   excessive level to obsolete items remaining in the
                                   inventory. However, the officials were unable to provide
                                   evidence that evaluations were performed to determine
                                   which items are obsolete.

                                   b.     Annual reconciliations of inventories of materials
                                          and supplies were not supported.

                                   The BMHA performs an annual physical inventory of
Physical inventories of
                                   materials and supplies, as required by HUD Handbook
Materials and supplies
                                   7510.1. However, the physical inventory is not reconciled
were not properly
                                   properly with the accounting records. Chapter 7 of the
reconciled
                                   Handbook provides that the differences between the
                                   physical inventory and the accounting records should be
                                   reconciled and any necessary adjustments should be made.
                                   The 1993 physical inventory amounted to $1,652,824,
                                   whereas, the general ledger balance was $1,904,728. The
                                   1994 physical inventory totaled $1,722,339, while the
                                   general ledger balance was $2,057,389. Rather than
                                   reconciling these differences, the BMHA wrote down the
                                   general ledger balances by $251,904 and $335,050,
                                   respectively, to match the physical count. Without proper
                                   reconciliations, the BMHA can not identify the causes of
                                   the differences to prevent them from recurring in the future.


                                           Page 19                                  96-NY-201-1002
Finding 3




                             c.     The BMHA does not properly value its inventory

                             Our audit disclosed several problems with the BMHA's
 Inventory not valued
                             Maintenance Costing System (MCS). The MCS does not
 correctly
                             record inventory values consistent with HUD Handbook
                             7510.1. Chapter 7, Paragraph (3) of the Handbook provides
                             that when items of materials are acquired at different dates
                             and at different prices, such items should be priced on the
                             "first-in, first-out, average price," or other acceptable
                             pricing method. The MCS values the inventory at the most
                             recent or last purchase price, which, in our opinion, is not
                             an acceptable pricing method because it often artificially
                             inflates the price of the aged items in the inventory.
                             Consequently, aged material and supplies are expended at
                             an inflated price.

                             In addition, the BMHA's inventory system consists of
                             numerous warehouses located throughout the BMHA. The
                             MCS is not programmed to generate an all-inclusive
                             inventory list. The MCS is limited to an inventory list per
                             warehouse. Without extensive manually computations, the
                             BMHA can not easily determine total inventory on-hand.
                             As a result, additional items may be purchased while in
                             stock. Also, the MCS does not generate a usage report that
                             provides the beginning balance, the number of items
                             purchased, the number of items consumed, and the ending
                             balance. As a result, the BMHA can not determine which
                             items are used frequently and which are obsolete.

                             We consider the weaknesses in the BMHA's controls over
 Significant weaknesses in
                             inventories for equipment, materials and supplies to be
 inventory controls
                             significant. Corrective actions must be taken to implement
                             controls that will ensure that equipment, materials and
                             supplies are properly accounted for and safeguarded; and
                             that purchases of nonexpendable equipment, materials, and
                             supplies are necessary and reasonable.



Auditee Comments             The BMHA's response provides that in the BMHA
                             reorganization, an independent Inventory Division was
                             created in the Administrative Department. All inventory
                             functions from all other departments were integrated within


96-NY-201-1002                       Page 20
                                                   Finding 3



this division. The director of this division is currently
evaluating various software which will address the
deficiency in the BMHA's current program and include an
inventory tracking program. The BMHA is revising the
purchasing system so that before a purchase order can be
assigned, the inventory department must verify that the
BMHA does not have a sufficient quantity in an effort to
get the inventory levels down.

The BMHA has scheduled an annual physical count of all
equipment to be done concurrent with the annual count of
the materials and supplies inventory by June 30, 1996. In
addition, the new Division of Inventory Control (a division
of Administrative Services) has been formed in order to
facilitate addressing the issues of expendable and non-
expendable inventory. This Division of Inventory, along
with the Audit Division, the Department of Finance and
Budgets as well as the newly created Division of Purchase
will work together to rectify the problems in the area of
inventory and to insure that these problems do not re-occur
in the future.

The Department of Finance and Budgets is working toward
establishing a computerized data base for all non-
expendable inventory items which will replace the manual
card system and which will serve as a basis for proper
inventory classification and reconciliation. Our target date
to complete this task is June 30, 1997.

Since September, 1995, the BMHA is now considering the
useful life of an item in addition to its cost when
determining whether to classify it as expendable or non-
expendable. Additionally, the BMHA will review its
Capitalization Policy and rewrite it as necessary in order to
establish guidelines for the proper classification of
inventory items.

By December 31, 1996, the BMHA's Disposition Policy
will also be reviewed and rewritten in order to establish a
systematic program for the identification and subsequent
removal of obsolete items from the materials and supplies
and the non-expendable equipment inventories. This
process should allow the BMHA to attain an accurate
assessment of its "useable" inventory by creating a uniform


        Page 21                                  96-NY-201-1002
Finding 3



                  approach to writing-off obsolete and missing and/or stolen
                  items.

                  The software which the BMHA currently uses for inventory
                  valuation has not lived up to its expectations and therefore
                  does not provide the necessary tools to properly value the
                  BMHA's inventory. The BMHA is currently in the process
                  of evaluating new software in many different areas,
                  including inventory. Officials of the BMHA anticipate
                  selecting new software by July 1, 1997. Hopefully, this will
                  result in the procurement of software which will adequately
                  address the issues of inventory valuation and the subsequent
                  expensing of the same. To date the BMHA has identified
                  and removed $27,589 of obsolete items out of its inventory.
                  The BMHA is planning to remove items on a semi-annual
                  basis.

                  Finally, the finding addressed the issue of equipment
                  belonging to the Federal program being used by the State
                  program. It is true that federally purchased equipment is
                  used by the State program on an as needed basis, however,
                  it is also true that equipment purchased by the state program
                  is used by the Federal program on an as needed basis.
                  However, the BMHA does recognize that equipment
                  permanently transferred from one program to the other
                  should be transferred to the appropriate property ledger and
                  charged to that program. This should be addressed in the
                  procedures manual currently being designed authority-wide.
                  A cohesive effort between Finance, Purchasing, Audit and
                  Inventory Control will provide effective procedures with
                  appropriate controls.



Recommendations   We recommend that you ensure that the BMHA:

                  3A.    Perform physical inventories of all equipment,
                         materials and supplies, and reconcile the results with
                         appropriate accounting records.

                  3B .   Consider the useful life of an item in its decision to
                         capitalize its cost.

                  3C.    Identify and remove all obsolete items from the
                         inventory; and develop and submit a plan to HUD


96-NY-201-1002            Page 22
                                              Finding 3



      outlining steps that will be taken to reduce the
      materials and supplies inventory to a reasonable
      level.

3D.   Use a Maintenance Costing System that values
      items in the inventory using an acceptable pricing
      method and produces useful inventory reports.




      Page 23                               96-NY-201-1002
Finding 3




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96-NY-201-1002                   Page 24
                                                                                         Finding 4




 The BMHA’s Unit Vacancy Rate Needs to be
                Reduced
The vacancy rate at the BMHA increased to the extent that at December 31, 1994, it had
exceeded 20 percent. The high rate is attributable to the BMHA's failure to perform unit
turnaround activities timely, which includes: (a) offering vacant units to applicants, (b) preparing
vacant units for reoccupancy, and (c) executing leases with prospective tenants. Additionally,
we believe that the number of units designated for the elderly or disabled may be greater than the
actual need; and is therefore having a negative impact on the BMHA's vacancy rate. As a result,
the housing needs of certain low-income applicants are not being met promptly.




                                Duri
  Background                    n g
                                the
                                past
three years the vacancy rate at the
BMHA increased from 25 percent to
34 percent. Specifically, the number
of vacant units escalated from 1,249
in 1992, to 1,705 at December 31,
1994, as shown in the graph below:




                                               Page 25                                 96-NY-201-1002
Finding 4




                              Unit turnaround activities are not performed timely

                              Section 201 of the BMHA's Annual Contribution Contract
  PHAs are to complete        (ACC) specifies that the Authority must operate the projects
  vacant unit turnaround      solely for the purpose of providing decent, safe and sanitary
  activities on the average   dwellings. In connection with accomplishing this objective,
  of 30 days                  Paragraph 5.2.c. of HUD Handbook 7460.7 REV-1, Field
                              Office Monitoring of Public Housing Agencies requires
                              PHAs to complete vacant unit turnaround activities on an
                              average of no more than 30 calendar days.

                              For Fiscal Year Ended June 30, 1994, BMHA's records
  Unit Turnaround time is     show that its unit turnaround time averaged 317 days,
  extremely excessive         which is extremely excessive when compared to the 30 day
                              requirement by HUD. Additionally, the results of our
                              review, which consisted of a sample of 22 units, showed
                              that it took the BMHA an average of 386 days to
                              turnaround a unit during our audit period. A breakdown of
                              the 386 days showed that from move-out to the time a unit
                              was assigned to the Vacant Apartment Preparation Crew
                              (VAPC) it took an average of 235 days. Also, it showed
                              that the VAPC took an average of 45 days to prepare the
                              units for reoccupancy. Additionally, the results showed that
                              it took an average of 106 days from the date a unit was
                              ready for occupancy to the date it was leased. In our
                              opinion, the above mentioned averages are excessive and
                              have caused units to remain vacant for extensive periods of
                              time, while unit turnaround activities are slowly completed.
                              Specific unit turnaround activities that are not being
                              completed timely are having a negative impact on the
                              BMHA's vacancy rate, as discussed in the subsections
                              below.

                                 a) The HUD prescribed system for offering units is
  It took an average of             having a negative impact on the vacancy rate
  235 days for a unit to
  become accepted by an       Under the BMHA's tenant selection process, a unit is
  applicant                   offered and accepted by an applicant before it is turned over


96-NY-201-1002                        Page 26
                                                                                    Finding 4



 to the VAPC to perform all necessary repairs. As previously stated, the results of our sample
 showed that it took an average of 235 days for a unit to become accepted by an applicant and
 turned over to VAPC. We attribute the extremely long period between a unit becoming
 vacant and being turned over to the VAPC to the plan (HUD's Plan B) used by the BMHA
 to offer units to applicants.

                                 Under HUD's Plan B, which is outlined in Public Housing
An applicant is offered          Occupancy Handbook 7465.1, an applicant is offered a unit
a unit at the three              at the three projects with the highest number of vacant
projects with the                units. Additionally, under a Voluntary Compliance
highest number of                Agreement, which resulted from a Title VI lawsuit, an
vacant units                     applicant is also offered a unit where his/her race is not
                                 predominant. Furthermore, the Voluntary Compliance
                                 Agreement requires that all applicants for a Section 8
                                 Housing Certificate be cross listed on the BMHA waiting
                                 list. The waiting list for a Section 8 Housing Certificate is
                                 maintained by the Rental Assistant Corporation of Buffalo.

                                 An evaluation of BMHA's use of HUD's Plan B to offer
90 percent of offers             units to applicants disclosed that 90 percent of the offers
were rejected                    were rejected. Based on available information, the crime
                                 rate and location of the projects is the major cause of the 90
                                 percent rejection rate. According to officials of the BMHA,
                                 the projects with the highest number of vacant units are the
                                 projects that are perceived to be the most undesirable;
                                 therefore, it is difficult to persuade applicants to accept
                                 units in those projects. In this regard, we noted that the
                                 BMHA has instituted measures to reduce the crime rate at
                                 targeted projects by participating in HUD's Safe Homes
                                 program. Among other initiatives, we noted that the
                                 BMHA has placed police substations in certain projects,
                                 instituted a drug intervention project, and started a police
                                 walking patrol program.

                                 During our audit, we conducted a survey of offers made by
Some applicants were             the BMHA in March, 1995 by sending letters to 422
not interested in a              applicants. At the completion of our audit field work, we
public housing unit              had received 100 responses. The results of the survey
                                 showed that some applicants had no interest in a public
                                 housing unit, but were interested in obtaining a Section 8
                                 Housing Certificate. These applicants were only put on the
                                 BMHA waiting list to comply with the requirement for
                                 cross listing the applicants with those on the list for a
                                 Section 8 Housing Certificate.


                                          Page 27                                 96-NY-201-1002
Finding 4



                                          Other applicants declined offers because they were only
 Results of Survey
                                          interested in units in particular BMHA projects that could
                                          not be offered under Plan B. The results of our survey are
                                          provided below:



       Number                        Reason why applicant did not accept the units offered

          13         The applicant was only interested in housing from the Rental Assistance
                     Corporation.

          55         The applicant was not interested in the particular unit offered, but were interested in
                     other units at the housing authority.

          32         Other reasons


                                          Apart from the above, we found that the units in certain
 Units in certain projects
                                          projects are generally precluded from being offered because
 are generally precluded
                                          they do not qualify as one of the locations with the largest
 from being offered
                                          number of vacancies. As a result, units in those project will
                                          remain vacant for a very long period of time or until
                                          revisions are made to the BMHA's offering plan (HUD's
                                          plan B) to allow units in those projects to be offered.

                                          (b) Units are not prepared for reoccupancy timely

                                          After units were accepted by prospective tenants and turned
 VAPC employees level of
                                          over to the VAPC, we determined that VAPC took an
 production was very low
                                          average of 45 days to prepare them for reoccupancy. Also,
                                          we determined that the VAPC's level of production was
                                          very low. We noted that in 1994, the average number of
                                          units prepared for reoccupancy by the VAPC, which consist
                                          of 39 employees, was 68 units per month, which is
                                          approximately 1.7 units per employee per month. The low
                                          number of units completed per month is even more
                                          significant when one takes into consideration that painting,
                                          flooring and some plastering of vacant units were
                                          contracted out.

                                          In order to evaluate the condition of the vacant units and to
 Vacant units should take
                                          estimate the amount of time needed to prepare a unit for
 only 1 to 2 days to
                                          reoccupancy, we inspected 25 of the 417 units that had been
 prepare for reoccupancy
                                          vacant for more than 6 months. All of the units inspected
                                          were in fairly good condition and could be ready for


96-NY-201-1002                                      Page 28
                                                                                    Finding 4



   occupancy within two days, and in some cases within one working day. Considering the
   above, the VAPC average of 45 days to prepare a unit for reoccupancy appears excessive.

                                 In addition, we noted that the VAPC is not following
                                 BMHA established procedure on trash removal from vacant
                                 units. BMHA personnel informed us that trash containing
                                 perishable items is removed immediately upon move out.
                                 However, during our inspections of the 25 vacant units for
                                 six months or longer we noted that raw trash, food stuff and
                                 personal possessions were still in many units. Such debris
                                 can attract and provide vermin with a place to live and
                                 become a health hazard to other tenants.

                                 (c) Leases are not executed timely with prospective tenants

An average of 106 days           The results of our sample of 22 units showed that after
for tenants to execute           vacant units were prepared for reoccupancy it took an
leases                           average of 106 days for tenants to execute leases and take
                                 possession. BMHA staff indicated that they are not able to
                                 give applicants a move-in date sooner because of the
                                 unpredictability of when a unit will be ready. Because of
                                 this, the BMHA advises applicants not to give notice to
                                 their current landlord until they are notified that their unit
                                 are ready. In this regard, the BMHA needs to develop a
                                 system to estimate the date a unit will be ready and
                                 establish a move-in date that will reduce the time between
                                 when a unit is ready and when the selected tenant takes
                                 possession.

                                 Number of units designated for the elderly and disabled is
                                 having a negative impact on vacancy rate

                                 At January 1, 1995, the BMHA had 370 vacant units for
Number of units
                                 elderly and disabled and only 303 applicants on its waiting
designated for the elderly
                                 list. Even if all the elderly applicants accepted a unit, the
may exceed the need
                                 BMHA would still have 67 vacant units designated for the
                                 elderly or disabled. This is an indication that the total
                                 number of units designated for the elderly or disabled may
                                 be greater than the actual need. For example, our review
                                 disclosed that at December 31, 1994, there were 39 vacant
                                 units designated for families, and 75 for the elderly and
                                 disabled at the Lakeview project. The review also disclosed
                                 that Lakeview is the project of choice for many family
                                 applicants; however, most of the vacant units are for the


                                         Page 29                                  96-NY-201-1002
Finding 4



                   elderly or disabled despite the fact that sixty two percent of
                   the vacancies in the project are third floor walk-up units.
                   Additionally, because many of the units have 3 bedrooms,
                   we question whether they are appropriately designated since
                   very few elderly applicants need or qualify for a 3 bedroom
                   unit. Thus, we believe that the BMHA should consider
                   converting some of the elderly walk-up buildings to family
                   use. This would allow more units to become available to
                   family applicants and also reduce the overall vacancy rate.



Auditee Comments   The BMHA's response provides that "the vacancy rate as of
                   12/31/95 was 26% - a reduction of 5.7% as compared to
                   12/31/94 (31.7%). The BMHA has established a Vacancy
                   Reduction Task Force which has one of it's goals a 10%
                   reduction target for 1996."

                   According to the BMHA's response, proposals to expand
                   the offer system, include tenant involvement in the
                   screening process, revise systems to speed up offers
                   (eliminate Crosslisting) and streamline other administrative
                   procedures are included in the Tenant Selection and
                   Assignment Plan proposals sent to HUD for approval on
                   7/18/95 and 12/1/95 (revised version). Officials of the
                   BMHA believe that further delays in the approval of that
                   plan continues to burden the BMHA in offering it's most
                   attractive housing stock. BMHA has been pursuing an open
                   choice offer system for minority applicants and five choices
                   based on the developments with the greatest percentage of
                   vacant for majority applicants.

                   The BMHA's Management Department is receiving
                   projections of turnovers from VAPC in a more timely
                   fashion. The projections are accurate and some turnovers
                   have been prepared before the projected date.

                   The newly created Vacancy Reduction Task Force is
                   successfully working toward reducing lease-up time for
                   applicants. The list of certified applicants waiting for
                   apartments to be completed is being reduced as VAPC
                   production increases (up to an average of 106 per months
                   and rising). However, applications are now being certified
                   in fewer days during recent months due to procedural
                   changes.


96-NY-201-1002             Page 30
                                                   Finding 4



Projected move-in dates are now identified for transfers,
certified applications, and applicants in the process of
certification. They are sent to the Managers for leasing
about two weeks before the anticipated apartment
completion date (for lease-up activity to begin), and the
Task Force is examining methods to send out applications
at least 30 days ahead of apartment preparation. When the
system has been tested and estimated completion dates can
be locked in, the pre-leasing of many units can occur.
Currently, most apartments are completed about one month
to one month and one-half after the applicant is certified.
As procution increases, this time will be reduced
significantly. This also means that in the future, a unit will
be scheduled for completion in anticipation of an applicant
accepting it.

Trash removal has been a problem for years. The existence
of raw trash in apartments may not be as extensive as
indicated in the finding. Record keeping was poor. A
database was being set up to resolve this and would be the
source to track what trash was removed and where
work/inspections are needed. Managers, upon completing
move-out inspections were to call in all work for raw trash
removal.

The BMHA is continuing to increase efforts under HUD's
Operation Safe Home through increase visibility at several
BMHA projects.

For Recommendation 4C, the Tenant Selection and
Assignment Plan submitted to HUD in December 1995
proposes to eliminate the crosslisting procedure.

The Vacancy Reduction Task Force was formed in
September 1995 to develop strategies and an action plan to
reduce vacancies by 10% each year over the next three
years.

BMHA is addressing the problem of designating elderly,
disabled, and family units. The BMHA is considering a
conversion of Lakeview walk-ups to families (4 buildings,
approved in CGP funding), and the demolition at A.D.
Price. In May 1996, the Board of Commissioners will be
asked to approve a change in the designation, from elderly


        Page 31                                  96-NY-201-1002
Finding 4



                    to single, of four buildings at Commodore Perry (100 units),
                    which will allow more units to become available to single
                    applicant and reduce the overall vacancy rate. We currently
                    have 2000 people on the singles waiting list.

OIG Evaluation of   The figures used in our graph and in our narrative came
Auditee Comments    directly from the BMHA's "Occupancy & Marketing
                    Department 1994 Report". Furthermore, our graph
                    indicates the time period that is depicted by the graph.

                    Regarding vacant units, our sample was selected from units
                    that had been vacant for more than six months. The results
                    of our inspections of vacant units disclosed that many units
                    were ready to be leased while others contained trash. In
                    this regard, we noted that units at four different projects
                    contained trash and that at least 11 were ready for
                    occupancy.



Recommendations     We recommend that you insure that the BMHA implement
                    procedures that will reduce the untimely completion of unit
                    turnaround activities to the extent that units are turned
                    around within 30 days from the date they become vacant.
                    Specifically, the BMHA should be instructed to:

                    4A.    Pursue revisions to the plan used to offer units to
                           applicants that will allow vacancies in all projects to
                           be filled timely, while maintaining a racially neutral
                           application process. For example, the BMHA could
                           change its offer system to allow units to be offered
                           in a project when its vacancy rate exceeds a
                           predetermined threshold vacancy rate of 3 percent.

                    4B.    Continue its positive efforts under HUD's Safe
                           Home Program to reduce the crime rate at targeted
                           projects.

                    4C.    Evaluate the current procedure of cross listing
                           applicants and pursue changes that would eliminate
                           the negative impacts on the vacancy rate. In this
                           regard, only those applicants who are interested in
                           obtaining either a Section 8 Housing Certificate or
                           a unit in public housing should be cross listed.



96-NY-201-1002              Page 32
                                               Finding 4



4D.   Initiate procedures to increase the productivity of
      the VAPC and/or consider contracting out the
      functions performed by that unit.

4E.   Consider redesignating units to meet the needs of
      the population; such as, converting one or more of
      the under utilized buildings for the elderly into
      buildings for tenants with families.




       Page 33                               96-NY-201-1002
Finding 4




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96-NY-201-1002                   Page 34
                                                                                         Finding 5




            The BMHA Needs to Improve Cash
                 Management Procedures

Our review disclosed that the BMHA: (a) did not invest its excess funds, (b) failed to periodically
solicit and evaluate its banking services, and (c) improperly used operating funds of the Federal
program to pay costs incurred by State projects. As a result, no investment income was earned,
banking services may not have been adequate, and funds for Federal projects were temporarily
used improperly. We believe that these conditions occurred because the BMHA's cash
management procedures in the areas of investing, banking, and requesting City funds were not
adequate.




                                      Section 401(E) of the Annual Contributions Contract (ACC)
 Criteria
                                      requires that excess funds on deposit in the General fund
                                      shall be invested in HUD-approved investment securities.
                                      HUD Handbook 7475.1 Financial Management Handbook
                                      assigns specific responsibilities to PHAs which include
                                      operating projects with maximum efficiency and economy.

                                      The primary goals of cash management procedures are to
 BMHA does not have
                                      assure the availability of cash for transactions, preserve the
 adequate cash
                                      value of cash resources, and earn maximum investment
 management procedures
                                      returns on excess funds until they are disbursed. We
 in certain areas
                                      reviewed the process of managing cash flow at the BMHA
                                      and found that it does not have adequate cash management
                                      procedures in certain areas. Specifically, we found that the
                                      BMHA: (1) has no investment policy and did not invest its
                                      excess funds, (2) did not perform periodic evaluations or
                                      solicitations for banking services, and (3) improperly used
                                      operating funds of the Federal program to pay costs
                                      incurred by State projects.

                                      Our review disclosed that during the audit period the
 BMHA did not invest
                                      BMHA did not invest its temporary excess funds. To
 excess fund
                                      determine the approximate amount of interest income that
                                      could have been earned if excess funds had been invested,
                                      we obtained the average monthly investable balance from
                                      the Analysis Summary Reports provided to us by the Bank.



                                              Page 35                                  96-NY-201-1002
Finding 5



                             We determined that, from July 1, 1993 to December 31,
                             1994, the monthly average investable balance was
                             $2,435,706.11.     Using 30 day Treasury bill rates,
                             approximately $146,551 of investment income would have
                             been earned if excess funds had been invested. Since
                             investment income reduces the amount of operating
                             subsidies provided to PHAs, the BMHA's failure to realize
                             such income may have caused HUD to approve and provide
                             more operating subsidies for 1994 than should have been
                             necessary.

                             We believe surplus funds were not invested because the
 The BMHA does not
                             BMHA does not have an investment policy. Such a policy
 have an investment
                             would allow for eligible investments, ensure that all excess
 policy
                             funds are properly invested, and designate who is
                             responsible for the supervision and management of the
                             funds invested.

                             Our review of current banking services disclosed that the
 Lack of adequate
                             BMHA has not maintained adequate knowledge of its
 knowledge of banking
                             banking services. Our review disclosed that the BMHA
 services
                             staff did not know exactly what services were provided to
                             the BMHA by the Bank, the cost of the services, or the
                             amount of temporary surplus funds available for
                             investments. According to HUD Handbook 7475.1 REV
                             CHG-1, 4-2 (C), "a PHA should know what bank services
                             it uses and the cost of the services to the PHA".

                             Additionally, we found that the BMHA did not periodically
 BMHA did not
                             perform solicitations for banking services. According to
 periodically perform
                             HUD Handbook 7475.1 REV CHG-1, 4-2(e)(1), banking
 solicitation for banking
                             services should be periodically solicited through
 services
                             competitive solicitation...in the form of a Request for
                             Proposals (RFP)." In this regard, we noted that the BMHA
                             has had its accounts with the same Bank since 1956 and
                             could not find any evidence that banking services had ever
                             been reviewed or that a competitive solicitation for banking
                             services had been performed. Therefore, the BMHA does
                             not have adequate assurance that bank services being
                             provided are adequate and their cost are reasonable.

 Funds for Federal           A review of the BMHA's revolving fund disclosed that
 projects were used to pay   Federal funds were routinely used to pay costs incurred
 costs of State projects     under State housing projects. This resulted from the


96-NY-201-1002                       Page 36
                                                                                     Finding 5



   BMHA's failure to timely bill the City for its share of costs incurred by State projects.
   Because of untimely billing, at August 28, 1995, the City owed the BMHA $1,270,265 for
   costs incurred by State projects for the six month period ended March 31, 1995.
   Consequently, Federal funds are being advanced through the revolving fund account to pay
   costs incurred by State projects. In our opinion, the use of operating funds of the Federal
   program to pay costs incurred by State projects violates Section 406 of the ACC, which
   states that PHA's will use operating receipts for costs which are necessary for project
   operations. In addition, funds advanced to pay costs of non-Federal activities are not
   available as surplus funds to be properly invested.



Auditee Comments                   The BMHA has implemented an investment plan and has
                                   earned over $19,000 in interest from August 1995 to
                                   December 1995. An RFP for banking services was issued
                                   and as a result banking is now done at M & T. All of the
                                   BMHA's accounts are now interest bearing and all banking
                                   fees have been waived by the bank. The BMHA hopes that
                                   when they get a new financial software package it will be
                                   more conducive to timely closing of the books and thereby
                                   allow for more timely reimbursement requests from the City
                                   of Buffalo.


Recommendations                    We recommend that you ensure that the BMHA has:

                                   5A.    Developed and adopted an adequate Investment
                                          Policy for investing excess cash.

                                   5B .   Procedures in place to continuously evaluate its
                                          banking services and obtain future services by
                                          competitive solicitation in the form of request for
                                          proposals.

                                   5C.    Developed and implemented requisition procedures
                                          to obtain timely payments from the City for its share
                                          of costs incurred by State projects. The
                                          implementation of the procedures should eliminate
                                          the need for the BMHA to advance operating funds
                                          of the Federal program to State projects to pay their
                                          operating costs.




                                           Page 37                                 96-NY-201-1002
Finding 5




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96-NY-201-1002                   Page 38
                                                                                         Finding 6




      The BMHA Needs to Improve Personnel
                 Practices

Our review disclosed various deficiencies in BMHA's administrative practices and controls.
Specifically, we found that: (1) staffing levels exceed HUD's suggested levels; (2) overtime costs
appear excessive; (3) controls over aspects of personnel and travel practices are not adequate; and
(4) Commissioners are receiving compensation in breach of the ACC. We attribute these
deficiencies to management's failure to: evaluate staffing levels; control the approval of
overtime; issue a written personnel policy; exercise management controls over travel practices;
and comply with the provision of its ACC that prohibit the use of Federal funds to pay
compensation to Commissioners. Consequently, the BMHA cannot assure HUD that its staffing
levels are necessary, that staffing costs, including overtime costs, are reasonable; or that travel
reimbursement claims were for needed and authorized activities. Furthermore, the unauthorized
compensation to the Commissioners has result in $32,825 of operating funds being used for
ineligible expenses.




                                      a. BMHA's staffing levels exceed HUD's suggested levels

                                      HUD Handbook 7460.7 REV-1, paragraph 2-3 provides
 Criteria
                                      guidance on evaluating the performance of a PHA. The
                                      guidance includes recommended staffing levels for housing
                                      authorities with more than 1,250 units. The recommended
                                      staffing levels for such PHAs provide for one maintenance
                                      employee for every forty units (1:40) and one
                                      administrative employee for every sixty five units (1:65).

                                      In February 1995, the BMHA had a total of 470 employees,
                                      of which 425 were paid from project funds of the Federal
                                      programs. Of the 425 employees charged to the Federal
                                      program, 387 were maintenance and administrative
                                      employees. When the BMHA's staffing levels are
                                      compared to HUD's recommended levels for PHA with
                                      more than 1,250 units, it discloses that the BMHA has as
                                      many as 187 more maintenance and administrative
                                      employees than HUD's guidance on staffing levels
                                      recommends, as shown below:




                                              Page 39                                  96-NY-201-1002
Finding 6




                                               Number of Employees

                                                 Actual        HUD          Number in
                                                 Number of     Guidelines   Excessive of
                                                 Employees                  Guidelines

                              Maintenance        227           124          +103

                              Administrative     160           76           + 84

                                TOTAL            387           200          +187


                           The number of employees shown in the above column
                           "HUD Guidelines" was determined by using the HUD
                           recommended ratios of 1 maintenance employees to every
                           40 units and one administrative employee to every 65 units.
                           In addition to determining that the current staffing levels are
                           excessive, we also noted that the BMHA's ratio of
                           employees to units has exceeded HUD's guidelines for the
                           past five fiscal years, which was discussed in a "General
                           Accounting Office (GAO) report, dated March 1, 1991. At
                           the date of the GAO report, which provided statistics as of
                           1990, the BMHA had 383 employees under its Federal
                           program. Since 1990, the BMHA has increased the number
                           of employees under its Federal program by 42. In our
                           opinion, the staffing levels at the BMHA needs to be
                           evaluated to determine whether they are excessive.

                           In conjunction with the above, we noted that the staffing
 Under utilized staffing
                           size of some departments may not be justified by the
 levels in some
                           amount of work being performed. For example, the staffing
 departments
                           size of the Management Department is not supported by the
                           amount of duties performed by that Department. For
                           instance, we noted that there are a total of 61 employees in
                           the Management Department, and that an average of 4 of
                           these employees is assigned to each of the BMHA's 11
                           management offices. Under the BMHA's organizational
                           structure, the Housing Managers at project sites are not
                           responsible for rent collections, Housing Quality Standards
                           inspections, tenant admission, or maintenance. They appear
                           to be only responsible for conducting tenant recertification
                           and being a contact point for the tenants. In our opinion, a
                           staff of 4 employees at each site appears excessive for the
                           duties assigned to Housing Managers. Moreover, in two
                           cases, we noted that the site offices for two projects are
                           either across the street or a courtyard from each other. To


96-NY-201-1002                     Page 40
                                                                              Finding 6



                           have 4 employees in each of those offices may not be
                           necessary or a practical use of staff resources.

                           Additionally, the ratio of supervisory personnel to non-
Number of supervisory
                           supervisory personnel in the BMHA's Accounting
positions in accounting
                           Department appears unreasonable. There is a supervisory
department may be
                           employee for every non-supervisory employee (1:1).
unreasonable
                           Further, we found two supervisory positions that do not
                           have nonsupervisory employees assigned to them.
                           Consequently, we believe that the number of supervisory
                           positions in the Accounting Department may be
                           unnecessary and unreasonable.

                           b. Controls over overtime costs are inadequate

                           In addition to high staff levels, the overtime costs at the
Overtime costs is very
                           BMHA is also very high. During our audit period, July 1,
high
                           1993 to December 31, 1994, the BMHA paid $2,102,137 in
                           reported overtime, which was approximately 12% of the
                           total salary costs of $18,041,164. Our review disclosed that
                           there is a lack of adequate controls over the authorization of
                           overtime, and that the BMHA does not have any formal
                           policy governing the approval of overtime. In some cases,
                           we found that overtime was not authorized in advance; that
                           overtime work was not supervised; and that there is
                           inadequate documentation showing that overtime work was
                           necessary. In our opinion, these deficiencies have
                           contributed to the BMHA's high overtime cost. In order to
                           reduce and prevent unnecessary overtime costs, we believe
                           that the BMHA should develop and implement a formal
                           policy governing the use and approval of overtime.

                           According to HUD Handbook 7401.1, Chapter 5, the local
BMHA does not have a
                           agency must formally adopt a personnel policy comparable
written Personnel Policy
                           to local public practice. At the time of our audit, the
                           BMHA did not have a written Personnel Policy.
                           Consequently, the BMHA does not have written procedures
                           to periodically evaluate the performance of all employees.
                           Permanent employees are not routinely given an annual
                           performance evaluation. The lack of evaluations adversely
                           impacts both the employees and the BMHA. In our
                           opinion, performance evaluations are needed to reward
                           good performers and to provide substandard performers
                           with feedback on areas where improvements are needed.


                                   Page 41                                  96-NY-201-1002
Finding 6



                         During the audit, we were told by the Administrator of
                         Personnel that her staff is currently writing a Personnel
                         Policy.

                         For our audit period, total travel cost contained expenses of
 Travel costs lack
                         $179,405 that represent reimbursements to employees for
 adequate supporting
                         local travel. The BMHA's travel policy allows for a $9.00
 documentation
                         per day flat rate for local travel, which is consistent with the
                         local government travel policy. However, HUD Handbook
                         7401.1 Chapter 5, states that if the local government has
                         officially adopted a policy for reimbursement for the use of
                         privately owned vehicles, the PHA may adopt the policy
                         subject to the PHA reimbursing based on: (1) mileage or (2)
                         a flat monthly allowance. Since the PHA is not reimbursing
                         employees for local travel based on mileage or a flat
                         monthly allowance, its policy of allowing a $9.00 per day
                         for local travel does not meet HUD's requirements.
                         Therefore, the BMHA's local travel policy of reimbursing
                         employees at an unsupported flat rate of $9.00 a day is
                         questionable. Accordingly, we believe that the BMHA
                         should revise its travel policy to require reimbursement for
                         local travel based on mileage.

                         Additionally, our review noted that various Commissioners
 Commissioner's local
                         were reimbursed for local travel costs totaling $7,204.
 travel reimbursements
                         These costs not only lacked supporting documentation, but
 appear unreasonable
                         in some cases appeared unreasonable. During our 18
                         months audit period, one commissioner claimed $9.00 for
                         local travel for 305 days while another put in claims for 274
                         days.     Such reimbursements appear excessive and
                         unreasonable. Thus, we believe that the BMHA should
                         require the Commissioners to provide documentary support
                         with claims for reimbursement for local travel.

                         Section 307(D) of the ACC provides that no funds of any
 BMHA Commissioners
                         project shall be used to pay compensation for services of
 received compensation
                         Board members of the local authority. During our audit
                         period, the BMHA paid members of its Board of
                         Commissioners, a total of $21,136. The BMHA also paid
                         health insurance and workmen's compensation coverage for
                         the Commissioners, which totalled $30,539. BMHA staff
                         indicated that those costs were paid with non-Federal funds.
                         However, our review disclosed that the total disbursement
                         of $51,675 were made from the revolving fund and that


96-NY-201-1002                    Page 42
                                                                      Finding 6



                   only $18,850 of the total amount was reimbursed from non-
                   Federal funds. Therefore, the remaining amount of $32,825
                   were made from the Federal program's operating fund.
                   Since the ACC and HUD Handbook requirements prohibit
                   any compensation for services rendered by Board members,
                   the BMHA should reimburse the Federal program's
                   operating fund $32,825, from non-Federal funds.



Auditee Comments   The BMHA response states that the ratios of average
                   number of administrative employees to units are intended
                   as guidance for purposes of assessing PHA staffing.
                   BMHA officials believe that the data is to be used as
                   indicators rather than standards; and that the geographic
                   locations (northwest vs. southeast), type of heating plans
                   (high pressure steamboilers vs. individual furnaces), types
                   of buildings (highrise vs. low rise) and type of construction
                   (brick vs. frame) should be considered in determining the
                   size of a PHA's staff. Officials advised that because of
                   Union agreements over the years, many of our maintenance
                   staff positions are so specialized that additional staff is
                   required to complete the work. Currently, the BMHA is in
                   negotiations with the Union in an attempt to combine some
                   maintenance titles or create new titles that would allow one
                   worker to do more than one trade.

                   The BMHA response provides that past HUD reviews did
                   not cite staffing as a problem. The Executive Director
                   contends that to the best of her knowledge, all previous
                   budgets and revisions were approved by HUD. Therefore,
                   HUD granted the approval and funding to operate at the
                   staffing level it did during the audit period.

                   The BMHA's response provides that the Housing Managers
                   do more than "conduct tenant recertification, and serves as
                   a contact point for the tenants..." They are charged with
                   enormous responsibilities and work diligently to provide a
                   variety of services for residents, employees, and the general
                   public. Not only do they proceed with the efficient dispatch
                   of those functions described in the response, and other
                   duties too numerous to set forth, they are expected to
                   continue to provide them with a shrinking staff.

                   The finding also points out that the Finance department has


                           Page 43                                  96-NY-201-1002
Finding 6



                 a high number of supervisory positions yet fails to point out
                 that supervision is a minor portion of 70% of those titles'
                 responsibilities. The BMHA further points out that it is
                 required to follow Civil Service law and must therefore
                 assign work according to Civil Service specifications. The
                 Specifications on an Assistant Accountant limit the type of
                 independent work and require a larger degree of
                 supervision. The Senior Accountant specifications do not
                 limit independent work and allows them to direct others that
                 are engaged in the same type of work (Assistant
                 Accountants and clerical staff).        Also, the Senior
                 specifications demand that they be supervised by someone
                 else who can make a decision and a recommendation to
                 another supervisor. Therefore, the BMHA also has the
                 Principal Accountant (overseeing 7) and an Assistant
                 Director (overseeing 5 and assisting the Director on
                 confidential matters).      In reality, the Seniors' job
                 specifications do not allow for analytical work either, it is
                 a point which could be argued by the Unions.

                 The BMHA response provides that it has establish
                 procedures to ensure that overtime work is necessary and
                 properly authorized.       In August 1995 the BMHA
                 established a "health and safety" priority for all overtime
                 work, as well as a requirement of the approval of the
                 Executive Director or the Assistant Executive Director. All
                 Department heads must also sign off on all requests for
                 overtime so as to ensure accountability.

                 The BMHA has completed a draft personnel policy manual
                 and it includes an implementation of performance
                 evaluation standards for all staff members. An outline of
                 the table of contents and performance evaluation section are
                 included in the BMHA comment. Moreover, currently all
                 supervisory personnel are being given supervisory training
                 by ECC, which includes performance evaluations. The
                 evaluation process will begin July 1st and will be based on
                 employee's anniversary date.

                 The BMHA plan to revise its reimbursement travel policy
                 on local travel to require documentary support and a basis
                 for reimbursement that comply with HUD requirements.

                 The BMHA has reimbursed the Revolving fund the entire


96-NY-201-1002           Page 44
                                                                   Finding 6



                  amount of funds on the books which were related to
                  "Commissioner's costs" from the NYS grant in aid. The
                  Commissioners have been requested to revise their current
                  benefit package by July 1, 1996.



Recommendations   We recommend that you ensure that the BMHA:

                  6A.    Evaluate and reduce staffing to the level needed to
                         administer its programs.

                  6B.    Establish procedures to ensure that overtime work is
                         necessary and properly authorized.

                  6C.    Develop a written personal policy that includes the
                         implementation of a annual performance evaluations
                         for all staff members.

                  6D.    Revise its reimbursement travel policy on local
                         travel to require documentary support and a basis
                         for reimbursement that comply with HUD
                         requirements.

                  6E.    Reimburse the Federal program's operating fund the
                         $32,825 that were paid to or on behalf of
                         Commissioners, from non-Federal funds.




                          Page 45                                96-NY-201-1002
Finding 6




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96-NY-201-1002                   Page 46
                                                                                   Finding 7




   The BMHA Needs to Implement a Uniform
      System to Process Purchase Orders


The BMHA's system for processing purchase orders is cumbersome and time consuming. This
deficiency occurred because the BMHA does not have a uniform system to process purchase
orders. As a result, unnecessary staff time is spent on a departmental basis performing
purchasing procedures and processing purchase orders, which have been so cumbersome and
time consuming that the BMHA has lost available discounts from vendors.



                                 Section 201 of the ACC provides that the Authority at all
 Criteria
                                 times will operate each Project in such a manner as to
                                 promote efficiency and economy. HUD Handbook 7460.8
                                 Chapter 3, Paragraph 3.2, provides that to assure that all
                                 staff are operating from a common system of procedures the
                                 Housing Authority should have a set of operational
                                 purchasing procedures designed for the working level, such
                                 as a handbook or standard operating procedures.

                                 Our review disclosed that the BMHA's procurement policy
 BMHA has not
                                 only provides information pertaining to the method of
 established written
                                 procurement and does not address standard operating
 procedures for processing
                                 procedures for processing purchase orders. As a result, each
 purchase orders
                                 department has created its own purchasing procedures. Top
                                 management of the BMHA has not examined these
                                 procedures to determine if they are working effectively for
                                 the individual departments or for the BMHA as a whole.
                                 Furthermore, the BMHA's Accounting Department has not
                                 established clear and concise written procedures outlining
                                 the payment process for purchases made using purchase
                                 orders. An examination of 30 executed purchase orders
                                 disclosed that they were all initiated after the BMHA
                                 received the item and paid the invoice.

                                 In addition, we found that the system for processing
 The system for
                                 purchase orders is cumbersome due to unnecessary steps
 processing purchase
                                 that have been added to the process over time. For example,
 orders is cumbersome
                                 the procedures require numerous signatures from low level



                                         Page 47                                 96-NY-201-1002
Finding 7



     management officials to the Executive Director. Most of the signatures do not provide any
     additional control within the process, but have increased the time it takes to process a
     purchase order. Our review disclosed that it took an average of 31 days to process a payment
     after the invoice was received. In addition, under the current process the purchase order is
     not typed until the requesting department receives a copy of the payment invoice from
     Accounting. We found that it took an average of 9 days for a purchase order to be typed,
     approved, and sent to Accounting. Afterward, it took an average of 22 days to be processed
     in Accounting. As a result of the lengthy process, we found instances where the BMHA was
     unable to take advantage of available discounts from vendors.

                                     In our opinion, the lack of a uniform system for processing
 The BMHA staff is being
                                     purchase orders has resulted in the unnecessary use of staff
 under utilized
                                     resources. Since each department has to procure its own
                                     goods, various employees in each department are used to
                                     perform the purchasing functions. Moreover, we found that
                                     personnel in one department are duplicating the tasks
                                     performed in another department. For example, Technical
                                     Operations performs a match of the purchase orders,
                                     receiving copies, and invoices. Likewise, the Accounting
                                     Department performs the same type of match. This
                                     duplication can be attributed to the individually established
                                     systems used to process purchase orders and a lack of
                                     communication between the departments.



Auditee Comments                     The BMHA's response provides that action was approved
                                     on March 25, 1996, that will allow for the elimination of the
                                     cumbersome signature process referred to in the finding.
                                     The BMHA has decided to adopt the changes recommended
                                     in Finding #7 and is in the process of implementing those
                                     changes.

Recommendations                      We recommend that you ensure that the BMHA:

                                     7A.     Establish and implement written purchase order
                                             procedures for the whole BMHA. These would
                                             include procedures for:


                                             1.   requesting items;
                                             2.   procuring items;
                                             3.   receiving items; and
                                             4.   accounting for purchase orders.


96-NY-201-1002                                Page 48
                                                 Finding 7



       The procedures must clearly define the
       responsibilities of the personnel administering the
       system.

7B .   Establish and implement methods to periodically
       evaluate the purchase order system to ensure that it
       is meeting its designed objectives.




        Page 49                                96-NY-201-1002
Finding 7




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96-NY-201-1002                   Page 50
                                                                                        Finding 8




  The Accuracy of the PHMAP Certification is
                Questionable

The BMHA's Public Housing Management Assessment Program (PHMAP) Certification as
submitted to HUD for the Fiscal Year Ended June 30, 1994 contained various conclusions that
were based on inaccurate information and data. The erroneous conclusions resulted from
incorrect calculations and improper procedures in computing the scores of some indicators and
the BMHA's failure to assure that computer generated data was accurate. As a result, the
PHMAP certification was assigned a higher score than it should have received, which resulted
in an inaccurate performer status for the BMHA. In our opinion, the inaccurate status prevented
the BMHA from being designated as troubled; thus, relieving it from having to execute a formal
Memorandum of Agreement with HUD to correct performance problems, and from HUD's
oversight and reporting requirements.




                                    HUD Regulations, 24 CFR 901.100, and Handbook 7460.5
 Criteria
                                    require PHAs to submit responses and a PHMAP
                                    certification within 90 days after their fiscal year begins for
                                    six indicators. Also, the regulations and Handbook
                                    instructions provide that the certification shall be for the
                                    information pertaining to the immediate past fiscal year and
                                    shall be based on actual data for each indicator. On
                                    September 29, 1994, the BMHA submitted its PHMAP
                                    certifications for the Fiscal Year Ended June 30, 1994. The
                                    certifications showed that the BMHA received a PHMAP
                                    score of 70 percent and was assigned a standard performer
                                    status by the HUD Buffalo Area Office. However, our
                                    review disclosed inaccuracies in the data used to score
                                    several indicators certified to by the BMHA. The results of
                                    our review are as follows:

                                    Indicator 1: Vacancy Number and Percentage.

                                    The BMHA certified to a .9 percent reduction of the actual
 Reduction in vacancy
                                    vacancies over the prior three years, which resulted in a
 percentage overstated
                                    PHMAP grade of E and 9 points for this indicator. Our
                                    review disclosed that there had not been a reduction in the
                                    percentage of vacant units. In fact, there was a 5.5 percent



                                            Page 51                                   96-NY-201-1002
Finding 8



                          increase in the actual number of vacancies which would
                          have resulted in a F grade and 0 points. In computing the
                          actual vacancy rate, the BMHA deducted the number of
                          vacant units proposed, scheduled and under modernization
                          from the total number of units vacant. This is not correct
                          according to Appendix 5 of HUD Handbook 7460.5, which
                          provides the HUD prescribed method for computing the
                          actual vacancy rate. The HUD prescribed way only
                          excludes those units funded and on-schedule under
                          modernization.

                          Indicator 6: Outstanding Work Orders

                          On the HUD-50072, PHMAP Certification form, the
 Work order data not
                          BMHA certified that 100% of emergency items were
 reliable or adequately
                          corrected or abated in 24 hours; that the percent of
 supported
                          outstanding work orders was 3%; and that progress had
                          been demonstrated in reducing the time required to
                          complete work orders. Our review disclosed serious
                          problems with the computerized work order tracking system
                          to the extent that the validity and veracity of the system is
                          highly questionable. We determined that maintenance
                          employees have access to the system to the degree that they
                          could go into the system and change categories, the amount
                          of materials used, the time, and other data items after work
                          orders have been completed and inputed into the system.
                          Also, the data used for the PHMAP scores did not agree
                          with the actual data in the system. For example, under
                          PHMAP, the BMHA indicated that there were 8 emergency
                          work orders in 1994 and all were completed in 24 hours.
                          Our review of the computer system indicated that there
                          were 30 emergency work orders in 1994. In addition,
                          included in the BMHA's system as work orders were
                          numerous non-maintenance items such as orders for
                          material, inspections, and cancelled work orders. As a
                          result, the number of total work orders in the system were
                          significantly higher than the actual number of maintenance
                          work orders. The artificially created high number of total
                          work orders caused the percentage of outstanding work
                          orders to be lower than it is in reality. Consequently, the
                          maximum score the BMHA received under this indicator
                          was not supported by the actual data.




96-NY-201-1002                    Page 52
                                                                             Finding 8




                          Indicator 7: Annual Inspections

                          This indicator has four components. Under this indicator,
 HQS inspections not
                          the BMHA certified on form HUD-50072, for FY 1994,
 performed on all units
                          that it has a system in place to track inspections and repairs
                          (component 1); that 100% of units had been inspected and
                          met Housing Quality Standards (HQS) (component 2); that
                          deficiencies in units were corrected in a average of 9.4 days
                          (component 3); and that the major systems were inspected
                          annually (component 4). Consequently, the BMHA's
                          PHMAP score was the maximum of 30 points. Our review
                          disclosed that the BMHA did not perform full HQS
                          inspections of vacant units because BMHA officials
                          believed that vacant units were not required to have full
                          HQS inspections. We disagree, inasmuch as HUD
                          Handbook 7460.5 provides that in computing the number of
                          units to be inspected, only units in a modernization program
                          or approved for demolition should be excluded. Since the
                          BMHA had over 1000 vacant units that had not been
                          inspected it should have received a grade of F under
                          component 2. Furthermore, of the 25 vacant units we
                          inspected, ten did not meet HQS due to existing
                          deficiencies. Therefore, the BMHA should not have
                          received a grade of A under component 3, which indicates
                          that all deficiencies in a unit had been corrected, and done
                          in 25 days or less. In our opinion, the BMHA should have
                          received a grade of F and 0 points under this component.

                          We believe that the accuracy of the BMHA's PHMAP
 BMHA's PHMAP score
                          certification is questionable and that the BMHA may have
 overstated
                          scored itself higher than it should have to avoid being
                          designated as a troubled authority. In our opinion, if the
                          PHMAP score for the above indicators had been properly
                          computed, the BMHA most likely would have received a
                          score of 60 or less and been designated as a troubled
                          authority.



Auditee Comments          The BMHA does not agree with the finding as follows:




                                  Page 53                                  96-NY-201-1002
Finding 8



                    Vacancy Number and Percentage

                    The BMHA's response provides that the BMHA calculated
                    its vacancy statistics using the 103 Annual Summary. It
                    further provides that our finding may have only taken into
                    account the Vacancy percentage as reported on the HUD
                    form 51234, which has no units deducted at all for
                    modernization.

                    Outstanding Work Orders

                    The BMHA's response provides that 30 Emergency work
                    orders from the computer needs to be adjusted for work
                    orders at State projects and for items that were not
                    emergencies. Also, BMHA officials do not feel that the
                    number of work orders is artificially high or that the number
                    of cancelled work orders is minimal.

                    Annual Inspections

                    BMHA officials believe that the statement that "BMHA
                    Officials believe that vacant units were not required to have
                    full HQS inspection" is not entirely accurate. Vacant units
                    were considered excused from inspections as compliance
                    with HQS would be insured prior to reoccupancy. They
                    further indicated that starting with 1992, the BMHA has
                    consistently inspected more than 100 percent of the units
                    required by PHMAP criteria.

OIG Evaluation of   Vacancy Number and Percentage
Auditee Comments
                    Our calculations of the Vacancy rate and percentage were
                    done in accordance with PHMAP requirements. In
                    addition, we reviewed a BMHA memorandum showing
                    vacancy data from Fiscal Year 1989 to Fiscal Year 1994.
                    The memorandum took into account units under
                    modernization and showed a increase in the number of
                    vacant units available as of December 31 from 1990 to
                    1993 along with a decrease in the occupancy percentage.

                    Outstanding Work Orders

                    As noted in Finding 2, the BMHA's work order system is
                    unreliable, inefficient and unsecured. As a result, the


96-NY-201-1002              Page 54
                                                                     Finding 8



                  PHMAP score for outstanding work orders was based on
                  unreliable information.

                  Annual Inspections

                  Our review indicated that all modernization vacant units did
                  not receive a complete HQS inspection. Also, our
                  inspection of 25 vacant units indicated that some vacant
                  units had uncorrected HQS deficiencies for over a year. As
                  a result, the certification that 100 percent of the units had
                  been inspected and meet HQS is questionable.




Recommendations   We recommend that appropriate staff of your office:

                  8A.    Work closely with the BMHA to ensure that its staff
                         is fully aware of the PHMAP criteria and the extent
                         and type of data required to support its PHMAP
                         certifications

                  8B.    Perform an on site confirmation review of the
                         BMHA's Fiscal Year 1995 PHMAP submission.




                          Page 55                                  96-NY-201-1002
Finding 8




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96-NY-201-1002                   Page 56
                                                                                         Finding 9




  Settlement Cost Should Have Been Allocated
             Among all Programs

The BMHA made all settlement payments to terminated employees from the Federal program's
operating fund. As a result, the Federal program was charged the entire amount of the settlement
payments instead of an allocated share in accordance with requirements of the Office of
Management and Budget, Circular A-87. According to PHA officials, the settlement payments,
which totalled $92,214 were made to avoid potential litigation, and at the time the decision was
made, consideration was not given to allocating the associated cost among all program
administered by the BMHA.




                                    The Office of Management and Budget Circular A-87, Cost
 Criteria
                                    Principles for State and Local Governments, provides that
                                    a cost is allocable to a particular cost object to the extent of
                                    the benefits received by the objective. Since settlement
                                    payments were made to employees connected with the
                                    overall administration of the BMHA, the associated cost
                                    should have been allocated among all the programs
                                    administered by the BMHA.

                                    Our audit disclosed that on July 28, 1995, the BMHA
 Settlement payments
                                    executed settlement agreements with three former top level
 charged to Federal
                                    employees, which provided for payments totalling $92,214.
 program
                                    Since the BMHA did not execute employment agreements
                                    with those employees, conditions pertaining to employment
                                    termination were not in writing. According to a PHA
                                    official, settlement payments were made to avoid litigation
                                    with the employees concerning their employment
                                    termination. The official also informed us that at the time
                                    the decision was made to make the settlement payments,
                                    allocating the associated cost among all programs was not
                                    considered.

                                    In a letter dated July 28, 1995, the local HUD Office
                                    informed the PHA that they had no objections to the
                                    settlement payments; and that "The payments should be
                                    made from non-Federal funding sources, e.g., rent receipts



                                             Page 57                                   96-NY-201-1002
Finding 9



                         or administrative fees earned from Section 8 properties".
                         Inasmuch as the settlement payments were made from the
                         Federal program's operating fund through the revolving
                         fund, we question whether non-Federal funds were used.
                         Also, we question the BMHA's decision to charge the entire
                         amount of the cost to the Federal program since the
                         terminated employees served all programs administered by
                         the BMHA, including the State program. Therefore, we
                         believe that the employee termination costs of $92,214
                         should be equitably allocated among all programs.

                         In reference to the above issue, we believe that the BMHA
 Written employment
                         should have written employment agreements with
 Agreements are needed
                         employees appointed by the Board of Commissioners.
                         Such Agreements should contain termination provisions
                         setting forth the conditions, reasons and procedures for
                         termination. Thus, reducing the possibility of potential
                         litigation due to employment termination, and the need to
                         make settlement payments to avoid potential litigation.



Auditee Comments         BMHA officials agreed that the finding is technically
                         correct; however they feel it would not be fair to require the
                         Authority to reimburse the appropriate portion of the
                         settlement costs from operating reserves. Also, the BMHA
                         indicated that current appointees will be requesting
                         employment agreements from the Board of Commissioners.


OIG Evaluation of        The crucial aspect of this finding is to recommend actions
Auditee Comments         that will assist in preventing the need to make settlement
                         payments to terminating employees in the future.
                         Therefore, we have revised our recommendations to require
                         the BMHA to execute employment agreements with certain
                         employees; and to allocate future settlement cost among all
                         programs administered by the BMHA, if appropriate.



Recommendations          We recommend that your office:

                         9A.    Ensure that all employees appointed by the Board of
                                Commissioners are covered by employment
                                agreements that contain termination provisions


96-NY-201-1002                   Page 58
                                                Finding 9



      setting forth the conditions, reasons and procedures
      for termination.

9B.   Instruct the BMHA to properly allocate all future
      settlement cost among all programs administered by
      the BMHA, if appropriate.




       Page 59                                96-NY-201-1002
Finding 9




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96-NY-201-1002                   Page 60
Other Matters
Project Based Accounting

HUD Regulations 24 CFR 990.320 require PHA's to certify that it is aware of and is taking steps
to implement project-based accounting and will produce the fiscal year-end reports required
under CFR 990.315. The BMHA made the required project based accounting certification for
its fiscal year beginning July 1, 1993 . However, the BMHA has not implemented a project-
based accounting system or produced the fiscal reports required under 24 CFR 990.315.

In addition to meeting the HUD requirements, a project based/cost center accounting system
would allow the BMHA to more readily identify problem projects so that corrective actions can
be taken promptly. Therefore, BMHA should contact the Buffalo Area Office to obtain more
information concerning the project based accounting requirements.




                                            Page 61                                96-NY-201-1002
Other Matters




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96-NY-201-1002                   Page 62
Internal Controls
In planning and performing our audit, we considered internal controls of the BMHA in order to
determine our auditing procedures and not provide assurance on internal controls. Internal
controls consist of a 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 is obtained, maintained, and
fairly disclosed in reports.




                                     We determined that the following internal controls related
 Internal Controls
                                     to the categories listed below were relevant to our audit
 Assessed
                                     objectives.

                                     •   Management Information Systems
                                     •   Maintenance
                                     •   Inventory Controls
                                     •   Nonexpendable Equipment
                                     •   Admission & Occupancy
                                     •   Travel
                                     •   Cash Management
                                     •   Procurement

                                     We evaluated all of the control categories identified above
                                     by determining the risk exposure and assessing control
                                     design and implementation.

                                     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.

                                     Based on our review, there are significant weaknesses in the
 BMHA has significant
                                     internal control areas cited in the Findings.
 weaknesses in internal
 controls
                                     •   Management Information Systems (Findings 1 thru 3)
                                     •   Maintenance (Finding 2)
                                     •   Inventory Controls (Finding 3)
                                     •   Nonexpendable Equipment (Finding 3)
                                     •   Admission & Occupancy (Finding 4)
                                     •   Cash Management (Finding 5)


                                              Page 63                                 96-NY-201-1002
Internal Controls



                    •   Travel (Finding 6)
                    •   Procurement (Finding 7)




96-NY-201-1002              Page 64
Follow Up On Prior Audits
The latest audit performed by an Independent Public Accountant (IPA) was for the period ending
June 30, 1994. The report did not contain any audit findings and there were no unresolved
findings from prior years.

In March 1991, GAO issued a report entitled Management Issues Pertaining to the Buffalo
Municipal Housing Authority. The report addressed issues concerning the potential effectiveness
of the voluntary compliance agreement, the BMHA's high vacancy rate, and the BMHA's staffing
levels exceeding HUD's guidelines. These issues are discussed in this report as part of Finding
3 and 5.




                                            Page 65                                96-NY-201-1002
Follow Up On Prior Audits




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96-NY-201-1002                      Page 66
                                                                         Appendix A

Distribution
Secretary's Representative, New York/New Jersey, 2AS
Director, Public Housing, Buffalo Area Office, 2CPH (2)
Director, Accounting Division, New York/New Jersey
Special Assistant, Buffalo Area Office, 2CS (3)
Assistant to the Deputy Secretary for Field Management, SDF, Room 7106
Deputy Assistant to the Secretary for Field Management, SDF, Room 7106
Office of Public and Indian Housing, PF (Attention: Comptroller, Room 4122) (3)
Acquisitions Librarian, AS (Room 8141)
(Acting) Chief Financial Officer, F (Room 10166) (2)
Deputy Chief Financial Officer, FF (Room 10166) (2)
Associate General Counsel, Office of Assisted Housing and Community Development, CD,
Room 8162
Assistant Director in Charge, US GAO, 820 lst Stret, NE Union Plaza, Building 2,
 Suite 150, Washington, DC (2)
Buffalo Municipal Housing Authority




                                       Page 67                            96-NY-201-1002
Appendix A




96-NY-201-1002   Page 68