oversight

Washington City HA, Washington, PA

Published by the Department of Housing and Urban Development, Office of Inspector General on 1996-12-23.

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

                                                                      Issue Date

                                                                           December 23, 1996
                                                                      Audit Case Number

                                                                           97-PH-202-1003




TO:            Paul LaMarca, Director, Public Housing Division,
               Pittsburgh Area Office, 3EPH


FROM:          Edward F. Momorella, District Inspector General for
               Audit, Mid-Atlantic, 3AGA

SUBJECT:       Washington County Housing Authority
               Management Operations
               Washington, Pennsylvania


Pursuant to your request we audited selected management operations of the housing programs
administered by the Washington County Housing Authority (Authority).

The purpose of the audit was to determine if the Authority administered its programs in compliance
with the Annual Contributions Contract and applicable HUD requirements.

Our audit found the Authority needs to improve operational controls covering the Drug Elimination
Program, Section 8 Program, and Public Housing Program occupancy.

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

Should you or your staff have any questions, please contact Irving I. Guss, Assistant District
Inspector General for Audit, at (215) 656-3401.
Management Memorandum




97-PH-202-1003          Page ii
Executive Summary
The purpose of the audit was to determine if the Authority administered selected aspects of its
housing programs in compliance with the Annual Contributions Contract and applicable HUD
requirements. Based on a survey of Authority operations, our audit focused on the Drug Elimination
Program, Section 8 Program and Public Housing Program operations covering occupancy,
procurement, disposition of non-expendable equipment, travel and cash receipts.

Our review of procurement, disposition of non-expendable equipment, travel and cash receipts
disclosed no reportable deficiencies.



                                         The Authority did not establish the baseline level of police
 Drug Elimination Program
                                         service and did not adequately monitor subgrantees as
 baseline activity not
                                         required. As a result $237,409 spent for police patrols is
 established
                                         unsupported. The Executive Director attributed the
                                         deficiencies to lack of staff.

                                         Review of the Section 8 Program revealed in some instances,
 Errors and omissions in
                                         as required, the Authority did not properly: (1) verify
 administering the Section 8
                                         income; (2) calculate total tenant payment; (3) verify a
 Program
                                         Federal preference; or (4) complete inspection reports.
                                         The deficiencies were mostly due to inadvertent mistakes
                                         by Authority staff. As a result, two tenants were overpaid
                                         and HUD paid excessive subsidy for another; a tenant
                                         without a Federal preference was unfairly housed ahead of
                                         others; and there is no assurance units initially and
                                         annually met Housing Quality Standards.

                                         Review of nine tenant files from four projects disclosed
 Public Housing Program
                                         instances where the Authority did not properly: (1) verify
 administration required
                                         income and dependent status; and (2) house tenants in
 improvement
                                         units of appropriate size. These deficiencies, while not
                                         numerous in any one area, were due to staff oversight and
                                         indicate the need for stronger internal controls over
                                         program administration. As a result, tenant rent was not
                                         correctly calculated, and tenants were overhoused.

                                     We recommend the Authority justify or repay HUD the
                                     unsupported payments to the Police Departments and ensure
                                     staff's compliance in administering housing programs
                                     requirements.




                                              Page iii                                  97-PH-202-1003
Executive Summary



                    We discussed the draft finding issues with Authority
                    representatives during the audit and where appropriate, their
                    comments are summarized in the findings. The draft findings
                    were provided to the Authority and the response received was
                    considered in our report. The Authority's written response is
                    included as Appendix B. The Executive Director declined an
                    exit conference.




97-PH-202-1003              Page iv
Table of Contents

Management Memorandum                                                 i


Executive Summary                                                    iii


Introduction                                                          1


Findings

    1      The Authority Needs To Improve
           Administration Of The Drug
           Elimination Program                                        3

    2      The Authority Needs To Improve
           Administration Of Its Section 8
           Program                                                    9

    3      The Authority Needs To Improve
           Certain Aspects Of Its Public
           Housing Program                                          13


Internal Controls                                                   17


Follow Up On Prior Audits                                           19


Appendices

    A      Schedule of Ineligible and Unsupported Costs             21

    B      Auditee Comments                                         23


                              Page v                      97-PH-202-1003
Table of Contents




         C       Distribution                                     27

Abbreviations
         CFR        Code of Federal Regulations
         HQS        Housing Quality Standards
         HUD        Department of Housing and Urban Development
         PHA        Public Housing Authority
         TTP        Total Tenant Payment




97-PH-202-1003                              Page vi
Introduction

The Washington County Housing Authority was established pursuant to the laws of the
Commonwealth of Pennsylvania to provide low rent housing for qualified individuals in accordance
with the rules and regulations prescribed by the Department of Housing and Urban Development.
The Authority's public housing inventory includes 1,002 dwelling units in conventional developments.
In addition, the Authority's Section 8 Program consists of 777 units.

The Authority received housing subsidies of $4,019,273 since 1994. The Authority has a five
member Board of Directors who are appointed by the Washington County Commissioners. The
Chairman of the Board is Peter Glasser. The Authority's Executive Director is Stephen Hall. The
Authority's Administrative Office is located at 100 Crumrine Tower, Franklin Street, Washington,
Pennsylvania.



                                          The primary objective of the audit was to determine whether
 Audit Objectives
                                          the Authority effectively managed its housing programs in
                                          compliance with the Annual Contributions Contract, and
                                          applicable HUD requirements. Based on survey results,
                                          the audit focused on the Drug Elimination and Section 8
                                          Programs, procurement, occupancy, and certain
                                          administrative operations.

                                          We reviewed pertinent Pittsburgh Area Office and Authority
 Audit Scope and
                                          records. We interviewed HUD and Authority staff,
 Methodology
                                          tenants and contractors. We also inspected three Section
                                          8 units.

                                      Audit Work was performed between April and November
                                      1996 and covered the period October 1, 1993 through
                                      February 28, 1996. The review was extended to include other
                                      periods where necessary.

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




                                               Page 1                                    97-PH-202-1003
Introduction




97-PH-202-1003   Page 2
                                                                                           Finding 1




         The Authority Needs To Improve
       Administration Of The Drug Elimination
                      Program

The Authority did not correctly establish the baseline level of police service and did not adequately
monitor subgrantees as required. As a result, $237,409 spent for police patrols is unsupported. The
Executive Director attributed the deficiencies to lack of staff.



                                      Baseline Services

                                      24 CFR 961.10(b)(2)(i) states:

                                      "Additional security and protective services
                                      to be funded under this program must be over
                                      and above those that the tribal, State or local
                                      government is contractually obligated to
                                      provide under its Cooperation Agreement
                                      with the applying HA .... An applicant
                                      seeking funding for this activity must first
                                      establish a baseline by describing the current
                                      level of services (in terms of the kinds of
                                      services provided, the number of officers and
                                      equipment and the actual percent of their
                                      time assigned to the developments proposed
                                      for funding) and then demonstrate to what
                                      extent the funded activity will represent an
                                      increase over this baseline."

                                      The Authority did not properly establish the baseline service
 Baseline service not
                                      provided by the Police Departments with whom the Authority
 established
                                      entered into a contract. According to the Executive Director,
                                      the Technical Assistance Contractor initially established the
                                      baseline services by talking on the phone with Washington
                                      PA's Police Chief. The baseline stated by this Police Chief
                                      was then projected to the other Police Departments. There
                                      was no documentation to support any discussions.




                                                Page 3                                   97-PH-202-1003
Finding 1




                 "Officer's Daily Reports" from the Donora PA Police
                 Department show the Department sometimes patrolled the
                 contracted area 16 to 24 hours per day. These patrols, paid
                 from the drug elimination grant, left little time for the Police
                 Department to perform services under the Cooperation
                 Agreement.

                 The Executive Director stated the Deputy Executive Director,
                 who has been on extended sick leave, was in charge of
                 overseeing the Drug Elimination Program. The Executive
                 Director stated you would have to know the problems the
                 Authority had at the project in order to appreciate what has
                 been done. Before the Drug Elimination Program funds were
                 utilized, there was open drug dealing and crime. Since the
                 patrols started, nothing goes on at the project.

                 Because the Authority did not establish the baseline level of
                 service provided by the Police, as required, the $237,409
                 spent on the service is unsupported.

                 Subgrantee Monitoring

                 24 CFR 961.28 states:

                 "... Grantees must monitor grant and
                 subgrant supported activities to assure
                 compliance with applicable Federal
                 requirements and that performance goals are
                 being achieved. Grantee monitoring must
                 cover each program, function or activity of
                 the grant."
                 Paragraph 3 of the contract between the Authority and one
                 Police Department states:

                 "... Two (2) police officers shall be present or
                 on patrol at Highland Terrace during all
                 hours of operation ...."




97-PH-202-1003            Page 4
                                                                            Finding 1




                       Paragraph 6 states:

                       "CONTRACTOR'S additional hours of
                       service for AUTHORITY'S public housing
                       development(s) provided pursuant to this
                       Agreement will include, but shall not be
                       limited to:

                       A. Perform vehicle and foot patrols in Highland Terrace and
                       Donora Townhouses ...."

                       The Authority did not adequately monitor the work of the
Authority's program
                       Police Departments with whom they contracted. A review of
monitoring deficient
                       the "Daily Reports" of the Cannonsburg PA Police
                       Department revealed the Department charged the drug
                       elimination grant for duties which should have been performed
                       under the Cooperation Agreement. For example, on February
                       12, 1996 two officers charged 17 hours to the drug
                       elimination grant (one officer charged 8 hours and another
                       charged 9 hours). The narrative says "Arrest and search
                       warrants ...." These are duties the Police Department would
                       be obligated to perform under the Cooperation Agreement.

                       The reports also show that officers charge time to the grant
                       when they leave the premises to respond to other calls. For
                       example, on March 31, 1996 the report shows an officer
                       worked from 20:45 to 21:45 and charged an hour to the grant.
                       The narrative says the officer "left to handle call 1513" and
                       then returned. There is no break in the time shown spent on
                       site.

                       The Authority also appeared to have been charged for
                       duplicate time. The same incident appears on two time sheets.
                       While the time sheets have consecutive days the badge
                       numbers, start and finish times, and narrative description were
                       identical. The Executive Director agreed and stated the Police
                       Department owes the Authority for the duplicate time
                       charged.

                       The review of the "Officer's Daily Reports" from the Donora
                       PA Police Department disclosed the department did not
                       adhere to the provisions in the contract. In most cases, two
                       officers were not present during patrols of the project. In


                                Page 5                                    97-PH-202-1003
Finding 1



                    addition, vehicle patrols were not always documented. The
                    Authority paid invoices for this Police Department without
                    receiving the supporting daily reports.
                    The Executive Director stated, to his knowledge the contract
                    had not been modified and the department may not have been
                    able to coordinate schedules of the officers in pairs because
                    the officers who patrol under the program are part-time.

                    Insufficient monitoring of Police Departments resulted in
                    departments receiving payment to perform duties which they
                    are required to perform by the Cooperation Agreement or
                    when they are not serving the Authority.



Auditee Comments    The Authority agreed with the finding but did not include the
                    recommendations in their plan of action to correct findings.
                    The Authority stated they will require the Chief of Police in
                    each jurisdiction to submit a letter stating the level of services
                    existing prior to grant activities. Further they will require
                    Police Departments who charged ineligible costs to the grant
                    to perform additional documented patrols free of charge to
                    compensate for the ineligible services.


OIG Evaluation of   While the Authority agreed to document the level of services
Auditee Comments    existing prior to the grant, they did not address repayment of
                    funds for any services which are not shown to be above the
                    baseline established. The Authority is not requiring repayment
                    from Police Departments which were paid for ineligible
                    services.

                    The Authority needs to repay, or require the Police
                    Departments to repay, any funds received for ineligible
                    services. Once the Police Departments have received payment
                    and/or the contract has expired, there is no guarantee they will
                    perform the additional documented patrols free of charge as
                    the Authority is requesting.




97-PH-202-1003               Page 6
                                                                    Finding 1



Recommendations   We recommend the Authority:

                  1A.   Establish the baseline services provided by the Police
                        Departments. Repay the grant for any of the $237,409
                        paid for patrols which are not shown to be above the
                        baseline established.

                  1B.   Provide adequate monitoring of all subgrantees and
                        withhold payment for those activities which should
                        have been performed under the Cooperation
                        Agreement and in accordance with the executed
                        contracts.




                          Page 7                                  97-PH-202-1003
Finding 1




97-PH-202-1003   Page 8
                                                                                              Finding 2




          The Authority Needs To Improve
        Administration Of Its Section 8 Program

Review of the Section 8 Program revealed in some instances, as required, the Authority did not
properly: (1) verify income; (2) calculate total tenant payment (TTP); (3) verify a Federal preference;
or (4) complete inspection reports. The deficiencies were mostly due to inadvertent mistakes by
Authority staff. As a result, two tenants were overpaid and HUD paid excessive subsidy for another;
a tenant without a Federal preference was unfairly housed ahead of others; and there is no assurance
units initially and annually met Housing Quality Standards (HQS).



                                       Income Verification

                                       24 CFR 882.116(c) requires:

                                       "... verification of family income and other
                                       factors relating to eligibility ..."

                                       For six of the 22 certification/recertification periods reviewed,
 Sampled periods disclosed
                                       the Authority did not properly verify income. For example, a
 income deficiencies
                                       tenant reported receiving Social Security benefits of $490 and
                                       $364 per month. The Authority used these amounts to
                                       calculate a TTP of $246 for the tenant. Verification with the
                                       Social Security Administration showed the tenant received
                                       only $490 per month. Therefore, the TTP should have been
                                       only $137. This incorrect payment was made for one month.
                                       When the tenant was recertified the correct payment was
                                       calculated. The tenant was not reimbursed the $109.

                                       For four of the six certification/recertification periods referred
                                       to above, the Authority failed to get appropriate certifications
                                       from adult members of households who claimed to receive no
                                       income. The Authority just took the word of the member.
                                       The Authority now has a form where the household member
                                       certifies to receiving no income.


                                       Because the Authority did not properly verify income, one
                                       tenant is owed $109. Also, without proper certification when



                                                 Page 9                                     97-PH-202-1003
Finding 2



                          a household member claims to have no income, it could not be
                          determined whether HUD paid excessive subsidy for these
                          tenants.

                          Calculation of TTP

                          24 CFR 813.106(a) states:

                          "Annual income is the anticipated total
                          income from all sources received by the
                          Family head and spouse (even if temporarily
                          absent) and by each additional member of
                          the Family, including all net income derived
                          from assets for the 12-month period
                          following the effective date of certification of
                          income ..."

                          24 CFR 813.102 defines adjusted income as:

                          "Annual income less the following
                          allowances, determined in accordance with
                          HUD instructions ... (e)(1) Child care
                          expenses..."

                          24 CFR 812.102 defines Child care expenses as:

                          "Amounts anticipated to be paid by the
                          Family for the care of children under 13
                          years of age during the period of which
                          Annual Income is computed ..."

                          The Authority did not properly calculate TTP for three of the
 Three TTP's improperly
                          certification/recertification periods reviewed. One improperly
 calculated
                          calculated TTP was the result of the Authority's failure to
                          properly verify income as shown in the previous section. In
                          the other instances, the Authority did not calculate income or
                          allowances to income correctly. For example, a tenant's pay
                          stubs showed bi-weekly income. In order to determine annual
                          income, the Authority averaged these pay stubs and then
                          multiplied them by 24 pay periods instead of 26 pay periods.




97-PH-202-1003                     Page 10
                                                                             Finding 2



                         As a result, one tenant overpaid $46 while another tenant
                         received excess subsidy of $60. The tenant overpayment for
                         the third tenant was addressed in the preceding section.

                         Verification of Federal Preferences

                         24 CFR 882.116(c) requires:

                         "... verification of family income and other
                         factors relating to eligibility ..."

                         The Authority did not properly verify a Federal preference
Errors in processing a
                         claimed by one of the two tenants reviewed who were
Federal preference
                         admitted during the audit period. In order to determine
                         whether the tenant qualified for the Federal preference, the
                         Authority used a rent receipt that showed rent which was
                         higher than the amount the tenant reported on earlier
                         correspondence. However, the Authority's files contained a
                         note that the tenant was not moving into the unit with the
                         higher rent. Also, the utility bill submitted did not have the
                         same address as the rent receipt.

                         Initially, the Section 8 Coordinator agreed the tenant did not
                         qualify for a Federal preference based on the information in
                         the file. Later, the Section 8 Coordinator said the tenant
                         provided additional information via the telephone. The
                         additional information, however, was not adequate to support
                         the tenant's claim of a Federal preference.

                         As a result, an applicant without a Federal preference was
                         placed ahead of applicants who qualified for a Federal
                         preference.

                         Unit Inspections

                         24 CFR 882.116(o) requires:

                         "Inspections prior to leasing and inspections
                         at least annually to determine that the units
                         are maintained in Decent, Safe, and Sanitary
                         condition ..."

                         24 CFR 882.109(c)(1) states:



                                 Page 11                                   97-PH-202-1003
Finding 2



                          "The dwelling unit shall afford the Family
                          adequate space and security."


                          24 CFR 882.109(c)(2) states:

                          "... Exterior doors and windows accessible
                          from outside the unit shall be lockable."

                          The Authority did not properly document the inspection
 HQS inspection reports
                          reports for 13 of the 18 inspections performed. The Authority
 improperly documented
                          used form HUD-52580 for these inspections, however, the
                          reports rarely indicated whether the items passed, failed, or
                          were inconclusive. For example, one report had only a check
                          in the pass column for a refrigerator in the unit. No other item
                          number was checked. Also, the report did not address unit
                          security.

                          We inspected three units which passed HQS. However,
                          without properly documented inspections, there is no
                          assurance the units met HQS prior to leasing and at least
                          annually as required.

                          Although the Section 8 Coordinator agreed with the
                          deficiencies, no explanation was given for their occurrence.
                          The Executive Director attributed most of the deficiencies to
                          mistakes.



Auditee Comments          The Authority concurred           with    the    finding    and
                          recommendations.




Recommendations           We recommend the Authority:

                          2A.    Verify income, allowances to income and Federal
                                 preferences in accordance with HUD requirements and
                                 calculate TTP based on these verifications.

                          We recommend your staff verify the Authority:




97-PH-202-1003                     Page 12
                                                                                           Finding 3



                                      2B.     Repaid $155 to the two tenants who paid excessive
                                              rents and repaid the program from non-Federal funds
                                              the $60 tenant underpayment.

                                      2C.     Adequately completes inspection forms to address all
                                              items required by 24 CFR 882.109.

       The Authority Needs To Improve Certain
        Aspects Of Its Public Housing Program
Review of nine tenant files from four projects disclosed instances where the Authority did not
properly: (1) verify income and dependent status; and (2) house tenants in units of appropriate size.
These deficiencies, while not numerous in any one area, were due to staff oversight and indicate the
need for stronger internal controls over program administration. As a result, tenant rent was not
correctly calculated, and tenants were overhoused.



                                      Verification of Income and Dependency

                                      24 CFR 913.109(a) states:

                                      "The PHA is responsible for determination of
                                      eligibility for admission; for determination of
                                      Annual Income, Adjusted Income and Total
                                      Tenant Payment; and for reexamination of
                                      family income and composition at least
                                      annually...."

                                      24 CFR 913.102 Definitions states:

                                      "Annual income less the following
                                      allowances, determined in accordance with
                                      HUD instructions:

                                      (a) $480
                                      for each
                                      Dependent
                                      "

                                      A dependent is defined as:




                                               Page 13                                   97-PH-202-1003
Finding 3



                           "A member of the Family household
                           (excluding foster children) other than the
                           Family head or spouse, who is under 18
                           years of age or is a Disabled Person or
                           Handicapped Person, or is a Full-time
                           student."




                               For two tenant files reviewed, the Authority did not verify
 Verification procedures
                               income or the dependent status of a family member. No
 require improvement
                               annual recertification was done in 1993 for one tenant.
                               For the other tenant, the Authority did not verify full-time
                               student status for an 18 year old household member even
                               though the tenant's rent was determined on a total income
                               adjusted by the $480 dependent allowance.

                           As a result, for one tenant, there is no assurance rent reflected
                           actual income and family composition, and for the other
                           tenant, rent was underpaid $120.

                           Overhoused Tenants

                           Section XII. B. of the Authority's Admission and Occupancy
                           Guidelines states:

                           "The adopted guidelines result in the
                           following range of persons per bedroom:"


                                                                  Number of Persons

                           Number of Bedrooms           Minimum                  Maximum

                                   0                       1                          1
                                   1                       1                          2
                                   2                       2                          4
                                   3                       3                          6
                                   4                       5                          8




97-PH-202-1003                         Page 14
                                                                                  Finding 3



                            Eight tenants at one project were overhoused. Six tenants
 Eight tenants overhoused
                            were overhoused in two-bedroom units and two tenants were
                            overhoused in three-bedroom units.

                            The Project Manager said the tenant files showed the tenants
                            needed to be transferred to one-bedroom units, but the
                            Authority did not have many of this size available to complete
                            the transfers. From January, 1993 to present, six one-
                            bedroom units became available for occupancy. Of those
                            available units, the Authority transferred tenants into four of
                            the units and moved people into the other two units. The
                            Project Manager did not address the two tenants who needed
                            to be moved from three-bedroom units to two-bedroom units.


                            Allowing tenants to remain in units which exceed the tenants'
                            needs results in excess subsidy paid on behalf of these tenants
                            and forces the families needing these units to remain on the
                            waiting list.

                            The Authority notified three tenants that they would be
                            transferred to the appropriate sized unit when they become
                            available.

                                                 ****

                            The Executive Director attributed most deficiencies to a lack
                            of internal controls due to staff remaining at one project for a
                            long time. The Authority tried to remedy this by rotating the
                            Assistant Project Managers. However, a grievance was filed
                            by one Assistant Project Manager and that Assistant Project
                            Manager was returned to the site where they worked for
                            years.



Auditee Comments            The Authority concurred with the finding and two of the three
                            recommendations. Regarding the transfer of tenants to the
                            correct size units, the Authority stated they would do this until
                            they amend their occupancy policy to allow tenants to be
                            overhoused during times of high vacancies.




                                     Page 15                                    97-PH-202-1003
Finding 3



OIG Evaluation of   Amending the occupancy policy is not a valid reason for not
Auditee Comments    transferring tenants when necessary. The Authority needs to
                    continue to transfer tenants as units become available.



Recommendations     We recommend the Authority:

                    3A.    Ensure that tenant files contain annual recertifications
                           and inspections and the documentation necessary to
                           support rent calculations.

                    3B.    Transfer all tenants who are overhoused as units
                           become available.

                    3C.    Provide training, supervisory oversight, and periodic
                           quality reviews of assistant project managers at
                           projects.




97-PH-202-1003              Page 16
Internal Controls
In planning and performing our audit, we considered internal control systems of the management of
the Washington County Housing Authority to determine our auditing procedures and not to provide
assurance on internal control. Internal control is the process by which an entity obtains reasonable
assurance as to achievement of specified objectives. Internal control consists of interrelated
components, including integrity, ethical values, competence, and the control environment which
includes establishing objectives, risk assessment, information systems, control procedures,
communication, managing change, and monitoring.

                                          We determined that the following internal control categories
 Internal controls assessed
                                          were relevant to our audit objectives:


                                      •   Procurement

                                      •   Occupancy

                                      •   Drug Elimination Program

                                      •   Section 8 Program

                                      •   Cash receipts

                                      •   Disposition of non-expendable equipment

                                      •   Travel

                                      A significant weakness exists if internal control does not give
 Significant weaknesses
                                      reasonable assurance that the entity's goals and objectives are
 found
                                      met; that resource use is consistent with laws, regulations, and
                                      policies; and 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, we believe the following items are significant
                                      weaknesses in the Authority's operations.

                                      •   Drug Elimination Program

                                      •   Section 8 Program




                                               Page 17                                    97-PH-202-1003
Internal Controls



                    •   Occupancy

                    These weaknesses are detailed in the findings in this report.




97-PH-202-1003              Page 18
Follow Up On Prior Audits
This is the first OIG audit of the Washington County Housing Authority.




                                             Page 19                      97-PH-202-1003
Follow Up On Prior Audits




97-PH-202-1003              Page 20
                                                                                     Appendix A

Schedule of Ineligible and
Unsupported Costs
Finding
Number         Ineligible 1/       Unsupported 2/

 1                                $237,409

 2              $215

               $215                $237,409




1/   Ineligible costs are not allowed by law, contract, HUD or local agency policies or
     regulations.

2/   Unsupported costs are not clearly eligible or ineligible but warrant being contested because
     of the lack of documentation supporting the need to incur such costs.




                                              Page 21                                97-PH-202-1003
Appendix A




97-PH-202-1003   Page 22
                             Appendix B

Auditee Comments




                   Page 23   97-PH-202-1003
Appendix B




97-PH-202-1003   Page 24
          Appendix B




Page 25   97-PH-202-1003
Appendix B




97-PH-202-1003   Page 26
                                                                             Appendix C

Distribution
Secretary's Representative, Mid-Atlantic, 3AS
Internal Control & Audit Resolution Staff, 3AFI
Director, Public Housing Division, Pittsburgh Area Office, 3EPH
Pittsburgh Area Coordinator, 3ES
Associate General Council Office of Asst Housing and CD, CD (Room 8162)
Assistant to the Deputy Secretary for Field Management, SDF (Room 7106)
Public and Indian Housing, Comptroller, PF (Room 5156)
Acquisitions Librarian, Library, AS (Room 8141)
Chief, Financial Officer, F (Room 10164)
Deputy Chief Financial Officer for Finance, FF (Room 10164)
Director, Housing and Community Development Issue Area, U.S. GAO, 441 G Street, NW, Room
2474, Washington, DC 20548




                                         Page 27                             97-PH-202-1003