Metropolitan Dade Housing Agency Public Housing Drug Elimination Program Miami, Florida

Published by the Department of Housing and Urban Development, Office of Inspector General on 1998-09-03.

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

                                                                     Issue Date
                                                                            September 1 , 1998

                                                                    Audit Case Number

TO:            Karen Cato-Turner, Director, Office of Public Housing, Florida State
                  Office, 4DPH

FROM:          Nancy H. Cooper
               District Inspector General for Audit-Southeast/Caribbean, 4AGA

SUBJECT:       Metropolitan Dade Housing Agency
               Public Housing Drug Elimination Program
               Miami, Florida

We have completed our review of the Metropolitan Dade Housing Agency’s (Agency) Public
Housing Drug Elimination Program (PHDEP) for fiscal years 1994 through 1996. The audit was
conducted as part of a nationwide audit of the PHDEP. The purpose of our review was to
determine whether the Agency administered and implemented its PHDEP in accordance with the
U. S. Department of Housing and Urban Development (HUD) requirements.

The report contains two findings requiring follow up action by your office. We will provide a
copy of this report to the Agency.

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

If you have any questions, please contact James D. McKay, Assistant District Inspector General
for Audit, at (404) 331-3369, or William W. Nixon, Senior Auditor, at (305) 536-5387.
Management Memorandum


98-AT-202-1008                 Page ii
Executive Summary
As part of a nationwide audit, we performed an audit of the Metro-Dade Housing Agency Public
Housing Drug Elimination Grants. The Agency received $8,345,250 in PHDEP funds between
1994 and 1996. Our audit objectives were to determine whether the Agency (1) implemented its
PHDEP awards for fiscal years 1994 through 1996 with satisfactory outcomes and benefits, (2)
prepared and submitted timely and accurate semi-annual and final Financial and Performance
Reports to HUD, (3) executed and monitored contracts with service providers, and (4) expended
PHDEP funds for only eligible activities in accordance with applicable requirements for the fiscal
years 1995 and 1996 grants.

The Agency lacked the necessary controls to properly monitor, evaluate, and report program
results. Specifically, the Agency did not (1) establish a system to measure and monitor its grants
to ensure that it met program objectives, (2) adequately report program results to HUD, (3)
execute and monitor contracts with service providers, and (4) maintain proper managerial and
accounting controls over its grants. As a consequence, the Agency expended $246,821 prior to
executing its grants and $355,020 on ineligible and unsupported activities. The Agency used
grant funds for such ineligible or unsupported activities as janitorial services, indirect costs,
Christmas and Kwanzaa events, salary expenses, field trips, and other ineligible or unsupported
activities. HUD should require the Agency to develop and implement the necessary management
controls to establish goals, measure performance, and ensure proper administration of its grants.
Further, HUD should require the Agency to reimburse its Drug Elimination Grant or the U.S.
Treasury for ineligible costs and to resolve unsupported costs.

We presented our findings to the Agency and HUD throughout the audit. We also held an exit
conference with the Agency on July 30, 1998. The Agency provided written comments to our
findings and has taken initial steps to correct some deficiencies. HUD’s Coral Gables Office also
provided written comments to our findings. We considered the responses in preparing our final
report. We have summarized the Agency’s responses for each finding and included the complete
response as Appendix B.

                                              Page iii                             98-AT-202-1008
Executive Summary


98-AT-202-1008                   Page iv
Table of Contents

Management Memorandum                                                    i

Executive Summary                                                    iii

Introduction                                                          1


1    The Agency Lacked Necessary Controls Over its PDHEP
     Grants                                                           3

2    The Agency Spent $601,841 on Ineligible and Unsupported
     Activities                                                     13

Management Controls                                                 23

Follow-Up on Prior Audits                                           25

      A Schedule of Ineligible and Unsupported Costs and
        Cost Efficiencies                                           27

      B Auditee Comments                                            29

      C Distribution                                                35

                                 Page v                    98-AT-202-1008
Table of Contents


CFR              Code of Federal Regulations
COPS             Community Oriented Policing
HRS              Health and Rehabilitative Services
HUD              U.S. Department of Housing and Urban Development
NOFA             Notice of Funds Availability
PHDEP            Public Housing Drug Elimination Program
PIH              Public and Indian Housing

98-AT-202-1008                           Page vi
The Metro-Dade Housing Agency is a division of the Miami-Dade County Government. The
Board of County Commissioners is the legislative and governing body of the County. The County
formed the Agency in May 1996 when it merged the Department of Housing and Urban
Development with the Department of Special Housing Programs. The Agency maintains
responsibility for housing and urban development projects for the County. The Agency manages
and operates over 11,000 public housing units.

The goals of the PHDEP were to eliminate drug-related crimes and problems associated with it
and encourage housing authorities and resident management corporations to develop a plan to
address drugs and other related problems. The plan should include prevention and intervention
initiatives that can be sustained over a period of several years. The Agency received PHDEP
funds in 1994, 1995, and 1996. The Agency applied for, but did not receive, PHDEP funds in
1997. The Agency’s Resident Services Department had the principal responsibility for
implementing the grants. The amount of funds awarded and reimbursed at May 22, 1998, were:

          PHDEP                  Funds                  Amount
         Fund Year              Awarded                Reimbursed             Balance
            1994               $2,792,500              $2,792,500                $0
            1995                2,792,500               2,792,500                 0
            1996                2,760,250               1,437,726             1,322,524
           Total               $8,345,250              $7,022,726            $1,322,524

HUD’s Jacksonville Office had responsibility for overseeing the Agency until HUD transferred the
duties to the Coral Gables Office in June 1997. Specific Notice of Funds Availability (NOFA) for
the grant and Title 24 of the Code of Federal Regulations (CFR) part 761 define HUD
requirements for PHDEP.

The Agency maintained its records at 1401 N.W. 7th Street, Miami, Florida.

                                    The overall audit objective was to determine if the Agency
 Audit objectives
                                    administered and implemented its PHDEP in accordance
                                    with HUD requirements. Specific audit objectives were to
                                    determine whether the Agency:

                                       •    Implemented its PHDEP awards for fiscal years 1994
                                            through 1996 with satisfactory outcomes and

                                              Page 1                             98-AT-202-1008

                     •   Prepared and submitted timely and accurate semi-
                         annual and final Financial and Performance Reports
                         to HUD.
                     •   Executed and monitored contracts with service
                     •   Expended PHDEP funds for only eligible activities in
                         accordance with applicable requirements for the fiscal
                         years 1995 and 1996 grants.

                   We reviewed the Agency’s controls and procedures over its
 Audit scope and   implementation of the program and administration of
 methodology       PHDEP grants awarded for fiscal years 1994 through 1996.
                   We reviewed the Agency’s PHDEP grant applications, grant
                   agreements, financial records, and performance and financial
                   reports. Further, we reviewed monitoring reviews by
                   HUD’s Jacksonville Office. We tested the eligibility and
                   support for costs, the success of the PHDEP, and service
                   provider contracts under the PHDEP. During our audit, we
                   interviewed Agency, Metro-Dade Police, and HUD staff.

                   To test for the eligibility and proper support for the
                   Agency’s expenditures, we selected 39 and 34 transactions
                   for its 1995 and 1996 grants, respectively. We randomly
                   selected the transactions from the Agency’s check register,
                   general voucher ledger, and payroll register with 59 of the
                   73 sample transactions from the check register. In some
                   instances, we expanded our review to include related

                   We performed our audit from February through May 1998.
                   The audit period covered January 1, 1995, through
                   February 28, 1998, and we extended the audit period as
                   necessary. We conducted our audit in accordance with
                   generally accepted government auditing standards.

98-AT-202-1008      Page 2
                                                                                        Finding 1

The Agency Lacked Necessary Controls Over
its PHDEP Grants
The Agency lacked the necessary controls to properly monitor, evaluate, and report program
results. Specifically, the Agency did not (1) establish a system to measure and monitor its grants
to ensure that it met program objectives, (2) adequately report program results to HUD, (3)
properly execute and monitor contracts with its service providers, and (4) maintain proper
accounting control over its grants. As a result, the Agency and HUD had no assurance that the
Agency accomplished program goals. Furthermore, the review disclosed $601,841 in ineligible
and unsupported costs. (See finding 2)

                                     Under 24 CFR part 761.35, the Agency was responsible for
 Program requirements                managing the day-to-day operations of the grant,
                                     monitoring activities to ensure compliance with applicable
                                     Federal requirements, and ensuring performance goals were

                                     HUD required the Agency to submit semi-annual financial
                                     and performance reports that evaluated the grantee’s
                                     performance against its plan. The performance reports were
                                     to include, among other information, the following in
                                     summary form:

                                        •   Any change or lack of change and explanation
                                            thereof in crime statistics or other indications drawn
                                            from the Agency’s plan assessment;
                                        •   Successful completion of the strategy components
                                            identified in the Agency’s plan;
                                        •   A discussion of any problems encountered in
                                            implementing the plan and how the Agency
                                            addressed it;
                                        •   An evaluation of whether the rate of progress met
                                        •   A discussion of the Agency’s efforts in encouraging
                                            resident participation; and
                                        •   A description of any other programs that it initiated,
                                            expanded, or deleted as a result of the plan, with an
                                            identification of the resources and the number of
                                            people involved in the programs and their relation to
                                            the plan.

                                               Page 3                              98-AT-202-1008
Finding 1

                           Also, 24 CFR part 761.35(b) required the Agency to submit
                           a final cumulative performance report within 90 days after
                           the end of the grant. During the audit period, Public and
                           Indian Housing (PIH) Notice 94-83 required the submission
                           of Semi-Annual Outcome Monitoring Reports. HUD did
                           not require the report after December 31, 1996.

                           Only the 1994 plan detailed a method for collecting and
 The Agency did not have
                           analyzing crime data. According to the plan, the Agency
 an effective system in
                           would collect crime data using activity logs, incidence
 place to measure and
                           reports and calls for police services. The Agency planned to
 monitor program results
                           compare and analyze data for the eight Community Oriented
                           Policing (COPS) sites.

                           The Agency received monthly reports containing crime data
                           for the COPS sites. However, the Agency did not review
                           and use the information to evaluate changes in drug-related
                           crime or perform an analysis to measure the impact of its
                           PHDEP Program on crime rates.

                           Each plan included surveys to gain information on residents’
                           perception of criminal activity, safety, and program
                           effectiveness. However, the Agency could not provide
                           surveys or other information to document that it conducted
                           such surveys or obtained comments from the residents.

                           Each plan stated it would use the Overall Tenant Advisory
                           Council (Council) to evaluate its program. The Agency
                           wanted the Council to perform an overall evaluation to
                           determine the most and least effective plan activities. The
                           Council did prepare one report that highlighted various
                           management problems. Issues raised in this February 1997
                           report included (1) lack of documentation for costs, (2)
                           concern that only 50-70 percent of the managers understood
                           the objectives of PHDEP, (3) lack of documentation and
                           benefit of the block captains and activity coordinators, and
                           (4) “a vast amount of misconception as to” what activities
                           management could pay for with PHDEP funds. The report
                           recommended better monitoring. The files did not indicate
                           that the Agency took action to correct these problems or
                           that the Council followed-up on its report or performed any
                           other evaluations.

                           Although required by HUD, the Agency did not collect,
                           analyze, and maintain vital information. Such information

98-AT-202-1008              Page 4
                                                                                                   Finding 1

                                                would include crime statistics and drug-related indicators,
                                                resident participation in and performance of activities,
                                                management indicators,1 and involvement of outside
                                                agencies. As a result of not collecting and analyzing the
                                                above information, the Agency could not measure the
                                                success of its programs or modify programs due to poor

                                                During the review period, the Agency violated HUD
     The Agency did not                         requirements by not submitting four performance reports or
     submit required reports to                 any Outcome Monitoring Reports for its grants.
     HUD                                        Furthermore, the Agency submitted the majority of the
                                                remaining financial and performance reports late. Agency
                                                officials explained they did not submit one report due to
                                                lack of activity. They could not explain why they did not
                                                submit the other reports.

                                                During the period January 1995 through December 1996,
                                                HUD required the Agency to submit semi-annual “Outcome
                                                Monitoring” reports. If completed, the reports contained
                                                information on crime statistics, performance indicators,
                                                management indicators, external linkages, and surveys. In
                                                PIH Notice 94-83, HUD stated:

                                                   “Measuring the impact of the PHDEP funds on crime
                                                   rates, resident participation in drug and crime prevention
                                                   measures, and overall resident and staff satisfaction with
                                                   local safety is necessary if HUD is to understand
                                                   program effectiveness, and modify programs to improve
                                                   the rate of drug and crime reduction in public and Indian

                                                Not only did the Agency need to provide the information to
                                                HUD, but the Agency needed to have the information to
                                                make its own evaluations and adjustments. Although HUD
                                                required the Agency to collect, analyze, and report such
                                                information, it did not.

                                                For the four Semi-Annual Performance Reports the Agency
                                                did not submit, HUD may have inadvertently recorded that
                                                it received the reports. HUD officials believed that if they
                                                recorded the reports as received, then the Agency must have
                                                submitted the reports. However, neither the Agency nor
                                                HUD could provide the reports. By incorrectly recording
    Such as vacancy rates, evictions, accounts receivable, etc.

                                                             Page 5                           98-AT-202-1008
Finding 1

                              that it received the reports, HUD allowed the Agency to
                              continue to draw down grant funds.

                              For performance reports submitted, the Agency did not
                              always include required information. Specifically, the
                              reports did not:

                                •       Contain information on the change or lack
                                        thereof in crime statistics.
                                •       Contain information on completion of “strategic
                                •       Compare the progress of actual activities to
                                        planned activities.
                                •       Include adequate information on resident
                                •       Describe other programs that the Agency
                                        initiated, expanded, or deleted as a result of its
                                        plan, and linkages with other service providers.

                              The reports only included information on the
                              implementation and continuance of some activities and
                              instances of problems encountered. Only one report stated
                              the number of people who participated in a field trip. Only
                              one service provider provided information on the population
                              served along with the ages, activities, and residency of
                              participants, which the Agency included in its reports.

                              Some reports provided HUD with misleading and
                              unsupported information. For example, one report stated
                              that the Resident College provided training and services to
                              block captains. However, the Resident College did not
                              operate during the reporting period. Resident College staff
                              stated that they had no knowledge of specific training
                              provided to block captains. Also, the reports claimed that
                              the Agency provided ongoing technical assistance, training,
                              and monitoring of the grants. The Agency did not provide
                              supplementary information to support the claims. Contrary
                              to the statements, the Agency did not collect and analyze
                              information on the effectiveness of its grants. The Agency
                              did not provide HUD with adequate information for HUD
                              to determine if the Agency achieved program objectives.
                              The Metro-Dade Police Department established a Public
  The Agency did not          Housing Police Section dedicated to patrolling eight of the
  monitor service providers   Agency’s developments. This section had approximately 34
  or negotiate the            officers and operated out of the Agency’s central office.
  agreements in the
  Agency’s best interest
98-AT-202-1008                 Page 6
                                                   Finding 1

The Agency reimbursed Metro-Dade Police Department for
the salaries of 15 officers. The county paid for the other
officers and related law enforcement equipment.

The NOFA required that the Agency execute a contract
with the local law enforcement agency before the Agency
could incur expenditures for this activity and/or HUD could
release the funds. However, the Agency did not execute an
agreement with the Metro-Dade Police Department for the
1995 grant. Officials believed that they did not need to have
an agreement since the same County Commissioners
oversaw both agencies. Without an agreement, the Agency
could not measure Metro-Dade Police Department’s
performance or assure it spent PHDEP funds economically
and efficiently.

Under the 1996 grant, the Agency reimbursed Metro-Dade
Police Department for overtime incurred by all the officers
assigned to the Public Housing Section. For the sample
transactions reviewed, the overtime reimbursements
amounted to over $37,000. The Agency budgeted $71,460
for overtime in its plan, but did not specify how this money
would be spent. The Agency entered into an agreement
with Metro-Dade Police Department for the 1996 grant.
However, the agreement did not provide for overtime
reimbursement. The agreement required Metro-Dade Police
Department to “provide coverage” with 15 officers “5 days
a week, 8 hours a day.” HUD requirements stated that the
reimbursements to Metro-Dade Police Department shall be
provided according to the contractual agreement. Since the
agreement did not provide for overtime, the Agency could
not support these costs.

Additionally, the invoices disclosed that a Metro-Dade
Police Department officer approved disbursements for
salaries and the Police Athletic League. An Agency official,
not a Metro-Dade Police Department officer, should
approve any disbursements of Agency funds. Some of these
expenditures may have been ineligible and unsupported.
HUD prohibited the use of PHDEP funds for “rallies,
marches, community celebrations and similar expenses.”
Also, a significant amount of the overtime went for officers
to participate in the Police Athletic League including
bowling and basketball. In future agreements with Metro-
Dade Police Department, the Agency should specify the

           Page 7                             98-AT-202-1008
Finding 1

                                            responsibilities, overtime activities, and the extent of

                                            The Agency entered into an $85,000 a year agreement with
                                            Artz ‘N the Hood for youth intervention services.
                                            Commissioners waived formal bid procedures to award this
                                            sole-source agreement. The agreement called for the
                                            Agency to reimburse Artz ‘N the Hood “for expenses
                                            incurred for program operation.” HUD requirements
                                            dictate that all costs “must be reasonable, necessary and
                                            justified with cost analysis.” The Agency did not analyze
                                            the reasonableness of costs to the number of participants.
                                            As a result, the Agency may have paid more for the services
                                            than necessary. Further, the Agency did not properly
                                            review invoices and allowed reimbursement for ineligible
                                            grant writing services (see Finding 2). Also, the agreement
                                            allowed Artz ‘N the Hood to determine whether it would
                                            renew the agreement for 2 additional years. The Agency,
                                            not Artz ‘N the Hood, should have the option to renew the
                                            contract based upon Artz ‘N the Hood’s performance.

                                            Similarly, the Agency paid the YMCA and Boy Scouts
                                            without benefit of competitive bidding, cost analysis, or an
                                            agreement. As with Artz ‘N the Hood, the Agency should
                                            consider a per child fee to negotiate and analyze proposed
                                            costs. The Director of Resident Services agreed and said
                                            they had recently negotiated a per child fee with the YMCA.
                                            Also, the Agency should execute written agreements that
                                            identify specific responsibilities, reporting procedures, and
                                            evaluation methods for measuring performance.

                                            The Florida Department of Health and Rehabilitative
                                            Services2 (HRS) provided intervention and prevention
                                            services to the Agency. The agreement stated that HRS
                                            would provide the Agency with monthly and quarterly
                                            reports of names and numbers of people assisted, calendar
                                            of events, and accomplishments. The Agency provided
                                            some reports at the exit conference. However, the Agency
                                            did not include this information in its performance reports,
                                            and there was no indication that the Agency utilized the
                                            information provided by HRS to monitor its grants or
                                            measure success. The Agency should ensure that it
                                            receives, reviews, and analyzes the reports to determine the
                                            success of the provider.
    The department changed its name to Department of Children and Families.

98-AT-202-1008                                Page 8
                                                                                               Finding 1

      The Agency lacked                      The Agency did not implement adequate accounting
      accounting controls over               controls over its grants. Specifically, the Agency did not:
      its grants
                                                 •    Reconcile grant expenditures to grant draw downs.
                                                 •    Properly authorize disbursements.
                                                 •    Properly authorize and document transfers between
                                                 •    Review audited financial statements.

                                             The Agency did not routinely reconcile HUD
                                             reimbursements with its expenditures. As a result, its
                                             reimbursements exceeded expenditures by $71,067 and
                                             $10,945 for the 1995 and 1996 grants, respectively.3 In
                                             some instances, the Agency received funds for checks that it
                                             subsequently voided. In other instances, the Agency
                                             transferred expenditures to other grants but did not
                                             appropriately offset the excess reimbursements. HUD
                                             required the Agency to disburse all grant funds within 7
                                             days, which the Agency may have violated. Staff agreed
                                             and stated they would eliminate the differences.

                                             The Agency did not spend all of its 1995 grant within the
                                             grant period. With a one time 6 month extension, the grant
                                             should have expired by February 24, 1998, (30 months after
                                             grant execution). HUD incorrectly entered into its system
                                             an expiration date of June 30, 1998. The Agency stated it
                                             would try to close out the grant as of February 1998. As of
                                             March 10, 1998, the Agency still had not expended $71,067
                                             from this grant.

                                             The Agency’s disbursement policy required that Resident
                                             Services officials approve invoices before payment. For
                                             three transactions reviewed, Accounting paid ineligible
                                             invoices that Resident Services did not properly approve.

                                             Both grants had a number of general journal vouchers,
                                             which moved significant amounts of expenditures between
                                             grants. In some instances the vouchers did not contain
                                             enough information to support the transfer or the official
                                             who approved the transfer. Finding 2 discusses ineligible or
                                             unsupported transfers of expenditures. The Agency should

    As of March 10 and February 28, 1998, respectively.

                                                          Page 9                          98-AT-202-1008
Finding 1

                            ensure that it documents the reason and approving official
                            for transfers of expenditures.

                            In several instances, Accounting inappropriately allocated or
                            changed allocations to Resident Services invoices.
                            Accounting did not notify Resident Services of the change
                            or the reason. Staff stated they would make the necessary
                            changes to correct such problems.

                            Management did not review the 1996 audited financial
                            statements.       The Independent Public Accountant
                            understated PHDEP revenue by $472,519 (15 percent).
                            Accounting staff provided possible explanations for the
                            error. However, the Agency should verify the accuracy of
                            audited financial statements.

   Lack of centralized      During the audit period, the Agency did not have an official
   control                  or group of officials to ensure that it implemented its
                            PHDEP with satisfactory outcomes and benefits. Although
                            Resident Services had general responsibility for the grants, it
                            did not exercise functional control over the grants. Each
                            site manager was responsible for preparing and
                            implementing a work plan, and for a period, approving
                            disbursements. Staff agreed that the Agency needed more
                            centralized control over the grant and had implemented
                            some new procedures.

   Agency reorganizations   The Agency went through a 2 year period of reorganizing
                            and restructuring staff positions and responsibilities,
                            including those associated with the PHDEP. The state of
                            change may have adversely affected the Agency’s ability to
                            effectively implement and monitor its PHDEP.

98-AT-202-1008               Page 10
                                                                      Finding 1

                    The Agency generally agreed with our finding and indicated
Auditee comments    that it was undertaking corrective action. The Agency
                    provided copies of HRS reports which we reviewed in
                    finalizing our report.

                    We believe the Agency’s proposed actions will strengthen
OIG evaluation of   its controls over the program. We amended the finding as
auditee comments    needed.

Recommendations     We recommend your office require the Agency to:

                    1A.    Develop and implement the necessary management
                           controls to measure performance and ensure proper
                           administration of its grants. At a minimum, the
                           controls should address how the Agency:

                              •   Collects, analyzes, and evaluates data on its
                              •   Reports results to HUD and others.
                              •   Measures, monitors, and reports on its
                                  service providers.
                              •   Authorizes and documents disbursements
                                  from and transfers between grants.
                              •   Reconciles grant expenditures to grant draw
                                  downs and timely offsets differences.
                              •   Reviews audited financial statements.

                    1B.    Determine the appropriate method of resolving the
                           discrepancy involving the 1995 grant termination

                    1C.    Improve its contract administration over service
                           providers to ensure proper execution and effective

                             Page 11                            98-AT-202-1008
Finding 1


98-AT-202-1008              Page 12
                                                                                        Finding 2

The Agency Spent $601,841 on Ineligible and
Unsupported Activities
Contrary to HUD requirements, the Agency spent $601,841 on ineligible and unsupported
activities. A review of 73 transactions disclosed the Agency inappropriately expended or could
not support grant funds for:

                    Description                   Ineligible        Unsupported
         Costs Prior to Grant Execution            $246,821
         Janitorial Services                        143,333
         Indirect Costs                               8,155               $46,303
         Christmas and Kwanzaa Events                21,237
         Salary                                      15,168                 64,498
         Field Trips                                  7,661                    350
         Other                                       27,845                 20,470

         Total                                     $470,220              $131,621

As discussed in Finding 1, the Agency lacked proper controls over its PHDEP grant and also
lacked sufficient supporting documentation for some of the expenditures. As a result, the Agency
did not properly implement its grant.

   Program requirements             Under 24 CFR 761.15(d)(2), the Agency could not use
                                    PHDEP funds for costs incurred before the effective date of
                                    the grant agreement.

                                    According to the NOFA, all costs must be reasonable,
                                    necessary, and justified with a cost analysis. Additionally,
                                    the NOFA required that the Agency use grant funds only for
                                    PHDEP purposes. The NOFA prohibited expenditures for
                                    indirect costs. Office of Management and Budget Circular
                                    A-87 defines indirect costs as those (a) incurred for a
                                    common or joint purpose benefiting more than one cost
                                    objective, and (b) not readily assignable to the cost
                                    objectives     specifically    benefited,  without    effort
                                    disproportionate to the results achieved.

                                    The NOFA allowed funding for costs such as meals and
                                    transportation, incurred for training and education activities
                                    directly related to “drug prevention programs to
                                    reduce/eliminate the use of illegal drugs.” The NOFA
                                    prohibited expenditures for fund raising, solicitations of

                                             Page 13                               98-AT-202-1008
Finding 2

                          gifts, rallies, marches, and community celebrations. Further,
                          the NOFA prohibited expenditures for entertainment,
                          amusements, or social activities and for related expenses
                          such as meals and transportation.

   Costs prior to grant   The Agency charged its 1994 PHDEP grant $162,193 for
   execution              costs incurred prior to grant execution on January 27, 1995.
                          The costs included security contracts and salaries for tenant
                          services and security personnel. Most of the costs occurred
                          between October 1994 and January 1995, although costs for
                          rental cars occurred as early as December 1993.

                          On February 2, 1997, by a general journal voucher, the
                          Agency transferred $122,995 of police salaries from its
                          1995 grant to its 1996 grant. The voucher did not provide
                          justification or need for the transfer. The salaries covered
                          the period of August 26 through November 3, 1996.
                          However, the Agency did not execute its 1996 grant until
                          October 21, 1996. Of the $122,995, $84,628 was for
                          services prior to grant execution and therefore ineligible.

   Janitorial services    The Agency expended $86,000 from its 1995 grant and
                          $57,333 from its 1994 grant for janitorial services at two
                          elderly developments.      The Agency did not list the
                          developments in its plans. Furthermore, the services did not
                          relate to PHDEP objectives. Staff believed that the
                          janitorial services related to a job training program.
                          However, the Agency could not provide support for its
                          position. Other information indicated that the Agency may
                          have charged the grants because the County stopped
                          providing funds that the Agency had used to pay for these

   Indirect costs         In the sample transactions reviewed, the Agency charged its
                          PHDEP grants $8,155 for costs of phones, beepers, and
                          copiers associated with the Resident Services department.
                          The Agency did not allocate these costs based upon usage
                          or benefit to the various grants administered by the
                          department. These expenditures were ineligible indirect

                          The Agency charged the grant $32,956 to lease 15 vehicles
                          from the County’s General Service Administration. The
                          NOFA allowed leasing of vehicles for activities directly
                          related to “programs to reduce the use of illegal drugs.”

98-AT-202-1008             Page 14
                                                                    Finding 2

                 The Agency could not support that the costs directly
                 benefited its PHDEP program or that it needed 15 vehicles.

                 Cursory review of the financial records revealed additional
                 similar payments of at least $13,347 to two vendors. Due
                 to numerous small transactions, we did not review or
                 compute the additional payments to the other vendors.

Christmas and    In December 1996 and 1997, the Agency violated HUD
Kwanzaa events   requirements by spending $21,237 on Christmas and
                 Kwanzaa events at several housing developments. The vast
                 majority of the funds went for gifts with the remaining going
                 for food and supplies for parties and reimbursements to the
                 staff. The gifts included a compact disc player, quartz
                 watches, a bike, and gift certificates for $25 and $50. The
                 supporting documentation did not indicate how these events
                 related to the Agency’s drug prevention program. The
                 events appeared to be social activities, community
                 celebrations, or entertainment rather than a drug prevention
                 program as defined by HUD requirements.

                 The Agency should have been aware that HUD prohibited
                 the use of PHDEP funds for such expenditures. On January
                 26, 1996, HUD informed the Agency of ineligible
                 expenditures from its 1995 PHDEP grant including $3,500
                 for Christmas gifts, $2,000 for refreshments, and $500 for
                 Christmas decorations. The Agency responded to HUD’s
                 letter by stating that none of the items noted by HUD “were
                 included in the invoices submitted to US HUD for
                 reimbursements.” In the same letter, the Agency stated that
                 it had credited the PHDEP account for other “ineligible
                 expenditures” including $2,000 for Christmas toys.

Salary           According to HUD requirements, the Agency could use
                 PHDEP funds for employee salaries provided:

                    •      All grant personnel must be necessary,
                           reasonable, and justified. The Agency must
                           provide job descriptions in the application for all
                           grant personnel.
                    •      Agency staff responsible for management and
                           coordination of PHDEP Programs shall be
                           compensated with grant funds only for work
                           performed directly for PHDEP grant-related

                          Page 15                              98-AT-202-1008
Finding 2

                            activities and shall document the time and activity
                            involved in accordance with 24 CFR 85.20

                 Ineligible salaries

                 The Agency inappropriately charged the grant for the salary
                 of a person who worked with the County’s General Service
                 Administration. Personnel incorrectly coded the person as a
                 police officer and Accounting charged the salary to its
                 PHDEP grants. For the transactions reviewed, the Agency
                 expended $3,848 for this person’s salary. Staff stated they
                 would credit the grant for the entire salary amount charged
                 to the grant.

                 Ineligible payments for temporary services

                 The Agency contracted for temporary employees.
                 According to staff, only two temporary employees spent
                 half of their time on the PHDEP grant. The Agency should
                 have charged the remaining temporary employees to other
                 programs. From the four transactions reviewed, the Agency
                 charged its PHDEP $9,318 for temporary employees not
                 assigned to the grant.

                 Excessive salary to Activity Coordinators and Block

                 The Agency hired residents as activity coordinators and
                 block captains to perform activities such as truancy patrols,
                 tutoring, and afternoon activities. The job descriptions
                 indicated that the stipend amounts were contingent upon
                 their skills and hours worked. The Director stated that the
                 Agency limited stipend payments to activity coordinators at
                 $200 per month. The review included eight payments to
                 activity coordinators and one payment to a block captain.
                 The Agency paid four activity coordinators a total of $1,902
                 over the limit. Another activity coordinator worked at a site
                 not listed in the plan; therefore, the $100 payment to her
                 was ineligible. Considering the hours worked, the Agency
                 could not support $150 paid to the block captain. The
                 Agency made additional payments to these individuals
                 which may also be ineligible or unsupported.

98-AT-202-1008    Page 16
                                                                                                Finding 2

                                              Unsupported salaries

                                              The Department Director allocated the employee salaries
                                              between the grants and or programs. According to staff,
                                              employees did not document actual time spent on specific
                                              activities and grants. Review of six payroll vouchers
                                              disclosed the Agency could not support and justify some of
                                              its payroll allocations. Specific instances of unreasonable
                                              allocations are as follows:

                                                   •    The Agency allocated the entire salary of the
                                                        former Director of Resident Services to PHDEP.
                                                        The Agency lacked support that the Director
                                                        spent all of her time on one grant.
                                                   •    An Administrative Officer stated that he spent
                                                        approximately 35 percent of his time on the
                                                        grant. The division director allocated his entire
                                                        salary to “Private Rental Housing.” However,
                                                        the Agency charged 100 percent of his salary to
                                                        the grant.
                                                   •    Other employees stated that they worked less
                                                        than 100 percent on the grant. However, the
                                                        Agency charged all their salaries to the PHDEP

                                              According to staff, they were in the process of changing the
                                              allocation to better reflect actual time spent on the grant.
                                              The Agency could not support $38,831 for the above
                                              employees charged to the grants for these six transactions.4

                                              Additionally, the Agency transferred salary costs of $25,517
                                              from another grant to its 1996 PHDEP grant. The voucher
                                              did not provide reasonable justification for the transfer or
                                              the activities performed for the PHDEP grant. One of the
                                              employees was on leave for the period transferred and thus
                                              could not have directly worked on PHDEP activities. Staff
                                              conjectured that the other grant ended, and the Department
                                              decided to charge the salaries to its PHDEP grant. The
                                              amount remains unsupported.

    This amount did not include fringe benefits.

                                                       Page 17                             98-AT-202-1008
Finding 2

   Field trips   According to its plan, the Agency was going to provide
                 “drug prevention and deterrence activities, such as ‘Just Say
                 No Youth Groups,’ after-school programs, parenting
                 training, youth community service projects, drug prevention
                 theme camps, musical and drama performances and anti-
                 drug rap groups, all targeting youth and families with
                 positive messages to avoid drug use.”

                 The Agency used funds to pay for the admission and
                 transportation of residents to local amusement parks and
                 movie theaters. The Agency could not support that it
                 expended the funds as part of a comprehensive drug
                 prevention program or how it selected participants. In
                 contrast to the events listed in its plans, the trips were for
                 entertainment and amusement rather than prevention and
                 education as required by HUD.

                 Ineligible expenditures of this type from our sample

                    •       $2,531 for admission to Santa’s Enchanted
                            Forest. The Agency also paid ineligible costs to
                            transport the residents to and from the
                            amusement park.
                    •       $2,470 for transportation of residents to attend a
                            free Christmas party at a local amusement park.
                    •       $1,020 for buses to take residents to movie
                            theaters. According to staff, the resident council
                            bought tickets for kids to attend the movies every
                            week during the summer, and PHDEP paid for
                            the transportation.
                    •       $525 for admission to Hot Wheels Skating
                            Center. The Agency paid $165 to bus the
                            children to and from the skating center.
                            Furthermore, the Agency expended another $350
                            to Hot Wheels Skating Center. This expenditure
                            was unsupported.
                    •       $490 for the admission of 70 residents into
                            Malibu Grand Prix. The Agency may also have
                            used PHDEP funds for transportation.
                    •       $460 for transportation to and from a bowling

98-AT-202-1008    Page 18
                                                           Finding 2

Other   The Agency paid the Police Athletic League $15,000 to
        take approximately 50 kids to the “Florida Sheriff Youth
        Ranch.” The documentation indicated only 14 of the 53 (26
        percent) children lived in public housing. It also included a
        profit of $2,084. As a result, the Agency's documentation
        could only support actual camp costs of $2,112 for the 14
        public housing children. The Agency spent at least $11,040
        for costs associated with the non public housing children.
        The Agency could not support the remaining $1,848.

        The Agency reimbursed Artz ‘N-the Hood a total of $3,579
        on two transactions for grant writing. According to
        members of the organization, the grant writer assisted in
        soliciting foundations and other sources for additional
        funding. HUD requirements prohibit PHDEP funds for
        “organized fund raising, financial campaigns, solicitation of
        gifts, etc.”

        The Agency reimbursed a management company $3,084 for
        expenditures incurred at a site not listed in its plan.
        Additionally, the Agency reimbursed another management
        company $2,689 in ineligible expenditures.         The
        expenditures consisted of $1,870 for transportation to
        Santa’s Enchanted Forest, Galaxy Skateway, Youth
        Museum, and others; $645 for mask making and dance
        workshops; and $174 for field trips.

        The Agency expended $2,422 on recreation equipment at a
        site not listed in its plan. Additionally, the Agency could
        not provide adequate documentation that this met PHDEP

        The Agency expended $2,100 for shirts and clocks that staff
        believed the Overall Tenant Advisory Council passed out to
        students. The expenditure did not meet the objectives of
        the PHDEP Program.

        The Agency expended $1,485 from its 1995 grant to
        provide Metro-Dade Police Department chairs and a desk.
        The activity did not relate to PHDEP objectives.

        The Agency used several general journal vouchers to
        transfer security guard expenditures from its 1994 PHDEP
        grant to various grants. The Agency transferred $13,923 of
        these costs to its 1995 PHDEP grant. It may have

                 Page 19                              98-AT-202-1008
Finding 2

                      transferred the costs to this grant because it did not have
                      enough funds in another grant. The Agency lacked
                      sufficient documentation to support the transfer.

                      The Agency expended $3,243 from its 1995 grant for video
                      and audio equipment for Scott Homes. The Agency
                      provided inconclusive documentation regarding eligibility of
                      this expenditure.

                      The Agency also used grant funds for these miscellaneous
                      ineligible and unsupported expenditures:

                        •        $880 for two cameras and film. According to the
                                 site manager, they used the camera and film for
                                 activities unrelated to its PHDEP. Further, the
                                 site manger sent and Accounting paid the invoice
                                 without proper approval.
                        •        $560 to purchase back to school supplies for
                                 children at a site not listed in its plan.
                        •        $6 for an inadvertent overpayment to the City of
                        •        $800 for a “Back to School Jamboree” for four
                                 sites. The Agency could not provide sufficient
                                 information concerning the actual activities
                                 performed to determine eligibility.
                        •        $656 for a “telephone maintenance fee” charged
                                 by the County on 35 telephones lines attributed
                                 to Metro-Dade Police Department. However,
                                 the Agency could not support the need and
                                 existence of 35 lines for Metro-Dade Police

                      The Agency generally agreed with the finding. However,
   Auditee comments
                      the Agency disagreed with our conclusions on indirect costs
                      and field trips. The Agency believed that it should be able
                      to charge “support cost” such as “beepers, pagers, and
                      copiers” to the grant. Agency officials believed the field
                      trips were drug intervention measures and “an important
                      deterrent to drug related criminal behavior.”

98-AT-202-1008         Page 20
                                                                       Finding 2

                     We agree that the Agency could have allocated the costs of
 OIG evaluation of
                     beepers, pagers, and copiers to the various grants based
 auditee comments
                     upon direct usage or benefit to the program. However, the
                     Agency did not allocate these costs among its various
                     grants, but charged the entire amount to its PHDEP grants.
                     The Agency provided no support for its contention that the
                     specific field trips mentioned in the finding “deterred drug
                     related criminal behavior” or how the field trips were
                     associated with other prevention efforts.

Recommendations      We recommend your office require the Agency to:

                     2A.    Reimburse its grants or repay HUD from non-federal
                            funds for the ineligible expenses of $470,220.

                     2B.    If permitted, request a waiver of 24 CFR
                            761.15(d)(2) for Metro-Dade Police Department
                            salaries incorrectly transferred to its 1996 grant or
                            reverse the transaction.

                     2C.    Reimburse its PHDEP grants, repay HUD from non-
                            federal funds, or provide adequate support for the
                            unsupported costs of $131,621.

                              Page 21                             98-AT-202-1008
Finding 2


98-AT-202-1008              Page 22
Management Controls
In planning and performing our audit, we obtained an understanding of the management controls that
were relevant to our audit. Management is responsible for establishing effective management controls.
Management controls, in the broadest sense, include the plan of organization, methods, and procedures
adopted by management to ensure that its goals are met. Management controls include the processes
for planning, organizing, directing, and controlling program operations. They include the systems for
measuring, reporting, and monitoring program performance.

                                      We determined the following management controls were
 Significant controls                 relevant to our audit objectives:

                                         •   Measurement and reporting of program results

                                         •   Eligibility of grant activities

                                         •   Disbursement of funds

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

                                      It is a significant weakness if management controls do not give
 Significant weaknesses               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 is obtained,
                                      maintained, and fairly disclosed in reports. Our review
                                      indicated that the Agency had significant weaknesses in its
                                      measurement and reporting of program results and determining
                                      the eligibility of activities. The weaknesses are described in the
                                      Findings section of this report.

                                               Page 23                                  98-AT-202-1008
Management Controls


98-AT-202-1008                   Page 24
Follow-Up on Prior Audits
This is the first Office of Inspector General audit of the Agency’s PHDEP grants.

The Agency’s independent audit report for fiscal year 1996, issued by Sharpton, Brunson &
Company, P.A., had no findings directly related to our audit objectives or results.

                                              Page 25                               98-AT-202-1008
Follow-Up on Prior Audits

                            (THIS PAGE LEFT BLANK INTENTIONALLY)

98-AT-202-1008                         Page 26
                                                                                                       Appendix A

Schedule of Ineligible and Unsupported Costs
and Cost Efficiencies

      Recommendation                  Ineligible5              Unsupported6                Cost Efficiency7

               1B                                                                               $71,067
               2A                      $470,220
               2C                                                $131,621

  Costs clearly not allowed by law, grant agreement, HUD, or local agency policies or regulations.
  Costs not clearly eligible or ineligible but which warrant being contested (e.g., lack of satisfactory documentation
  to support the eligibility of the cost, etc.).
  Efficiencies are an estimate of future savings from recommendations which prevent improper obligations, avoid
  more unneeded expenditures, or increase revenues.

                                                     Page 27                                         98-AT-202-1008
Appendix A


98-AT-202-1008              Page 28
                               Appendix B

Auditee Comments

                   Page 29   98-AT-202-1008
Appendix B

       Page 2
       OIG Response

       The Agency has a decentralized management system in place to ensure that the lowest level of
       services are provided at the appropriate agency level to the users and promote efficiency. Under
       our PHDEP structure the Residents Development Division served as the overall grant coordinator
       for MDHA. Our current policy is that the Resident Development Division reviews all invoices
       for payment.

       The Agency will occasionally receive a request as stated before to adjust the cost allocated to
       various programs, because of a number of factors; and to comply with PHDEP requirements. It
       is important to note that if an over reimbursement occurs to the PHDEP LOCCS system, the
       PHA is powerless to return the funds since USHUD policy does not allow this. What then results
       is an automatic audit finding that gives the appearance that the Agency requested funds from
       PHDEP posted a credit but never adjusted the records to reflect the changes.

       We are in the process of establishing a Grant Coordinator position to handle the authorization,
       reconciliation, transfers, and financial statements.

       The Agency was given written approval by USHUD to extend the 1995 grant period through
       June 30, 1998. As of this date the grant has been closed out.

       Program Requirements

       In accordance with the grant application, the agency planned and implemented a program for the
       Overall Tenant Advisory Council (OTAC) to measure and monitor our program. OTAC
       members implemented their plans and were paid for their collection of data. We are in the
       process of finalizing a comprehensive plan to monitor the program through MDHA's Office of

       Required Reports

       Staff has completed the missing reports and submitted them to USHUD and the OIG auditors
       completing this audit. (see attached copies)

       Monitor Service Providers or Negotiate the Agreements

       A purchase order was issued for the YMCA as a sole source vendor through the County's
       General Services Administration Procurement Office. This purchase order is renewed annually
       by the County's Procurement office to ensure eligibility for payment.

98-AT-202-1008                              Page 30
                                                                                           Appendix B

Page 3
OIG Response

The Florida Department of Children & Family (C&F) formerly known as HRS provides
intervention and prevention services to our residents. We have all reports from C&F.

We are in the process of crediting 1997 grant for the expenditures of temporary personnel which
was inappropriately allocated or changed by the Accounting Department without notice.

Lack of Centralized Control

In February, 1996, MDHA requested that one third of our grant award be reprogrammed to be
used mainly for our PRIDE-Block Captain and LEEAP programs. In doing that we were
decentralizing the expenditures and giving our site managers responsibility of how to spend
funds. This request was approved by USHUD on April 23, 1996.

We are now in the process of centralizing the program once again with the Grant Coordinator
overseeing the whole program. We have fiscal control of the remaining funds and have
established with Accounting limited signatures.

Finding 2:

The Agency spent $639,452 on ineligible and unsupported activities

Contrary to HUD requirements, the Agency spent $639,452 on ineligible and unsupported
activities. A review of 70 transactions disclosed the Agency inappropriately expended or could
not support grant funds for:

        Description                          Ineligible                  Unsupported

  Costs Prior to Grant Execution             $246,821
  Janitorial Services                         143,333
  Indirect Costs                                8,155                        $ 46,302
  Christmas and Kwanzaa Events                 21,237
  Salary                                       15,169                         64,497
  Metro-Dade Police Dept. Expenditures          1,485                         38,268
  Field Trips                                   7,661                            350
  Other                                        26,360                         19,814
  Total                                      $470,221                       $169,231

Janitorial Services

The Agency concurs that $143,333 in janitorial services at two elderly developments appears to
be not related to the PHDEP and should be disallowed.

                                              Page 31                                   98-AT-202-1008
Appendix B

       Page 4
       OIG Response

       Indirect Cost

       The Agency believes that the staff of the Resident Development division that are appropriately
       providing PHDEP related services should be able to complete their assigned task with the aide of
       beepers, pagers and copiers. The PHDEP activities could not be done without these support cost.

       Agency Salaries

       As a County department, Miami-Dade County has pay manuals and collective bargaining
       agreements that govern compensation (including overtime). MDHA has taken corrective action
       and has appropriately distributed staff salaries amongst the various funding sources.

       Ineligible salaries $3,849, for the Agency concurs that the salary of one individual was
       inadvertently charged to the grant by mistake and should be disallowed. Accounting will
       reimburse the charge to the PHDEP. We are in the process of crediting the grants that were
       inappropriately charged for temporary personnel.

       Metro-Dade Police Department Expenditures

       Again, we do not feel that an agreement is necessary, between MDHA and MDPD. MDHA is
       not a separate authority in that in accordance with state law, Miami-Dade County is a single
       governmental entity. Interagency agreements are permitted, as are scopes of services, etc.
       However, these agreements do not supersede County policy. Overtime pay for certain employee
       classifications is required, and is approved by the Board of County Commissioners in collective
       bargaining agreements.

       The MDPD Police Athletic League (PAL) funds the sports activities and basketball games in
       which the Public Housing Police Section (PHPS) are participants. The overtime was authorized
       by USHUD in the original grant application.

       While the program under the PDHEP funds 15 officers (one lieutenant, three sergeants, and 11
       officers) assigned to 11 developments in unincorporated Miami-Dade county, the police
       department provides funding for 27 additional officers (one lieutenant, three sergeants, and 23
       officers) to augment police services to public housing developments. With the assignment of the
       additional personnel, the Section is able to provide coverage five days a week, 16 hours a day,
       from 7:00 am in the morning to 10:00 PM at night. The additional officers assigned to the
       program enhance the ability of the County to provide increased police presence, conduct surveys
       to assess social services needs, and to combat drug related crimes and other criminal activity.
       The County's contribution of police services in support of the grant far exceeds the amount

98-AT-202-1008                              Page 32
                                                                                               Appendix B

 Page 5
 OIG Response

 Field Trips

 Traditionally, whenever school is out, the incidence for drug and alcohol use as well as criminal
 behavior increases. The holiday events and field trips were drug intervention activities. We
 believe that by providing positive, supervised activities where children and their families bond in
 a safe drug free environment, is an important deterrent to drug related criminal behavior.

 The Agency did not review audited financial statements.

 The Agency's policy requires that the Chief Accountant and staff review drafts of the audited
 financial statements and make comments/recommendations to the Independent Public
 Accountant (IPA) prior to finalizing the audit and presenting it to management. This procedure
 to review the 1996 audit report was followed, however, after the exit meeting with management
 the IPA issued a report with different revenue figures from those shown in Agency's general
 ledger. The Accounting staff had observed errors in the IPA's software program and brought this
 to the IPA's attention for correction. The Agency is no longer under contract with the
 Independent Public Accountant from 1996, but will ensure that similar errors do not occur with
 the current IPA.

 If you have any further questions, please feel free to call Tawana Thompson at 305-644-5100.

cc:       Tawana Thompson
          Al Brewster
          Raul Fernandez
          Cassandra Smith

                                                 Page 33                                    98-AT-202-1008
Appendix B


98-AT-202-1008              Page 34
                                                                         Appendix C

Secretary's Representative, 4AS
State Coordinator, Florida State Office
Director , Office of Public Housing, 4DPH
Audit Liaison Officer, 3AFI
Director , Administrative Service Center, 4AA
Acquisitions Librarian, Library, AS (Room 8141)
General Counsel, C (Room 10214)
Associate General Counsel, Office of Assisted Housing and Community Development,
  CD (Room 8162)
Counsel to the IG, GC
Public Affairs Officer, G
HUD OIG Webmaster-Electronic format via Electronic mail-
Director, HUD Enforcement Center, 1240 Maryland Avenue, Suite 200, Washington, DC 20024
Chief Financial Officer, F (Room 10166) (2)
Deputy Chief Financial Officer for Finance, FF (Room 10164) (2)
Director, Office of Budget, FO (Room 3270)
Director, Housing and Community Development Issue Area, U.S. GAO, 441 G Street N.W.,
  Room 2474, Washington DC 20548
Assistant Secretary for Public and Indian Housing, P (Room 4100)
Comptroller/Audit Liaison Officer for Public and Indian Housing, PF (Room 5156) (3)
Assistant to the Deputy Secretary for Field Management, SDF (Room 7106)
Assistant to the Secretary for Labor Relations, SLD (Room 7118)
The Honorable John Glenn, Ranking Member, Committee on Governmental Affairs,
  United States Senate, Washington DC 20515-4305
The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs,
  United States Senate, Washington DC 20515-4305
The Honorable Dan Burton, Chairman, Committee on Government Reform and Oversight,
  United States House of Representatives, Washington DC 20515-6143
Mr. Pete Sessions, Government Reform and Oversight Committee, Congress of the United
  States, House of Representatives, Washington, DC 20510-6250
Ms. Cindy Sprunger, Subcommittee on General Oversight and Investigations, Room 212,
  O'Neil Office Building, Washington DC 20515
Director, Metropolitan Dade Housing Authority

                                  Page 35                              98-AT-202-1008