oversight

Metro Atlanta Task Force for the Homeless, Inc. Innovative and Supportive Housing Homeless Programs Atlanta, Georgia

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 3, 1998

                                                                   Audit Case Number
                                                                          98-AT 251-1009




TO:            John Perry, Director, Office of Community Planning and
                  Development, 4AD


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

SUBJECT:       Metro Atlanta Task Force for the Homeless, Inc.
               Innovative and Supportive Housing Homeless Programs
               Atlanta, Georgia

We completed an audit of the Innovative Homeless Program (IHP) and Supportive Housing
Program (SHP) administered by the Metro Atlanta Task Force for the Homeless, Inc. (MATFH).
We conducted the audit at the request of HUD’s Georgia State Office. Our objectives were to
determine whether the Task Force administered its grant programs in an efficient, effective, and
economical manner, and in compliance with the Department of Housing and Urban Development
(HUD) regulations.

The Task Force did not efficiently and effectively manage its programs to ensure compliance with
regulations. As a result, MATFH spent $1,243,854 of IHP grant funds without proper support.
Also, MATFH charged $6,607 of ineligible administrative costs to the IHP grant. In addition,
the Task Force did not adequately maintain its accounting records or monitor the subrecipients
under its SHP grant.

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

Should you have any questions, please contact Sonya D. Lucas, Assistant District Inspector
General for Audit, at (404) 331-3369. We are providing a copy of this final report to the Metro
Atlanta Task Force for the Homeless, Inc.
Management Memorandum




                 (THIS PAGE LEFT BLANK INTENTIONALLY)




98-AT-251-1009                 Page ii
Executive Summary
We completed an audit of MATFH’s administration of its Innovative and Supportive Housing
Homeless Programs. The objectives of the audit were to determine if the grantee administered its
IHP and SHP grants in an efficient, effective, and economical manner, and in compliance with
terms and conditions of the regulations.

We determined that the Task Force did not efficiently and effectively manage its programs to
ensure compliance with regulations.

Specifically, the audit disclosed:

     •       The Task Force did not effectively administer its 1994 and 1995 IHP for which it
             received over $1.9 million in HUD funding. MATFH did not: (1) adequately
             document payments to subrecipients; (2) ensure that the 1995 IHP subrecipients
             properly determined client eligibility; (3) maintain sufficient records to demonstrate
             that clients were served as proposed in its grant application; (4) require the
             subrecipients to submit audits; and (5) close-out its 1995 IHP program as required.
             Consequently, we identified $1,243,854 of unsupported costs and $6,607 of ineligible
             costs charged to the 1994 and 1995 IHP grants. As a result, the Task Force could
             not measure its grant performance, and we were not assured that the resources were
             assisting the homeless persons intended to be served by the program.

     •       The Task Force did not maintain proper accounting records for its $12.4 million
             received in SHP funds. MATFH’s costs were not properly documented or
             supported, and reimbursements to subrecipients were untimely. Consequently,
             MATFH reimbursed subrecipients $66,427 in unsupported costs, paid $760 of
             ineligible program costs, and charged $8,824 of ineligible administrative costs from
             the SHP grant. As a result, we could not obtain reasonable assurance of the
             accountability of the SHP program funds.

     •       The Task Force did not adequately monitor the subrecipients under its SHP.
             Specifically, MATFH did not: (1) perform monitoring visits in accordance with the
             terms of its contract; (2) monitor the submission of Annual Performance Reports; and
             (3) require the subrecipients to document client eligibility, or obtain financial audits.
             As a result, the Task Force could not demonstrate the impact SHP funding had on
             the homeless population or whether the subrecipients served the number of
             individuals proposed in its grant applications.


                                       We recommend HUD require the Task Force to repay HUD
   Recommendations
                                       for all ineligible costs and resolve unsupported costs;
                                       provide documentation to support the eligibility of clients
                                       served; establish accounting records to support the receipts
                                       and use of SHP funds and administrative costs; implement
                                       procedures for reviewing and approving SHP requisitions

                                                Page iii                               98-AT-251-1009
Executive Summary


                    for payments; implement cash management procedures to
                    ensure timely reimbursements to SHP subrecipients; and
                    implement monitoring reviews of SHP subrecipients for
                    program services and financial management.

                    We presented our findings to the Task Force and HUD’s
 Exit conference
                    Georgia State Office officials during the audit. We held an
                    exit conference on July 29, 1998. The Task Force provided
                    written comments to our findings. HUD’s Georgia State
                    Office of Community Planning and Development also
                    provided      written     comments         and    suggested
                    recommendations to our findings. We considered the
                    comments and suggested recommendations in preparing our
                    final report. We included excerpts from the Task Force’s
                    comments in each finding and the complete comments as
                    Appendix B.




98-AT-251-1009          Page iv
Table of Contents

Management Memorandum                                                i


Executive Summary                                                iii


Introduction                                                        1


Findings

1    Innovative Homeless Program Was Not Effectively
     Administered                                                3


2    Accounting Records Needed Improvement                      11


3    Inadequate Monitoring of Subrecipients                     21



Management Controls                                             31


Follow Up On Prior Audits                                       33

Appendices
      A Schedule of Unsupported and Ineligible Costs           35

      B Auditee Comments                                        37

      C Distribution                                            47




                                  Page v               98-AT-251-1009
Table of Contents


Abbreviations:

CFR              Code of Federal Regulations
HUD              Department of Housing and Urban Development
IHP              Innovative Homeless Program
MATFH            Metro Atlanta Task Force for the Homeless
OMB              Office of Management and Budget
SHP              Supportive Housing Program




98-AT-251-1009                       Page vi
Introduction
Background     Metro Atlanta Task Force for the Homeless, Inc. is a non-
 Background
               profit organization incorporated in 1986. The Task Force’s
               purpose is to coordinate the creation of programs and the
               provision of services to address the problem of
               homelessness. The Task Force is the central coordinating
               agency for services to homeless shelters in the metropolitan
               Atlanta area. The Task Force offers a wide range of
               services, such as providing government grant funds to
               subrecipient agencies to strengthen and increase the services
               provided to homeless persons. The Task Force is the 24-
               hour emergency placement facility for homeless persons in
               the metropolitan Atlanta area, which assists between 2,000
               and 3,000 homeless people every month in finding new
               housing options. It also serves as the central clearinghouse
               for continuing services, the organizer of the local coalition
               of service providers, and the point agency for advocacy and
               information on the causes and conditions of homelessness.

               HUD awarded the Task Force two Innovative Homeless
               Program grants for 1994 and 1995 in the amount of
               $997,500 each. The 1994 grant was used to fill gaps within
               the context of developing a system to combat homelessness.
               The focus of the 1995 grant was aggressive outreach and
               assistance to help homeless persons most affected by the
               harsh winter weather.

               Additionally in July 1995, MATFH was awarded a
               $12,451,233 HUD Supportive Housing Program grant to
               provide supportive services and housing for homeless
               people. The purpose of the SHP grant was to help
               individuals and families move from homelessness to
               permanent housing and self-sufficiency. Metro Atlanta Task
               Force for the Homeless executed the $12.4 million grant
               agreements with HUD on behalf of 16 subrecipients,
               including itself, that were approved for funding under the
               SHP grant award.




                        Page 1                               98-AT-251-1009
Introduction


                    The Metro Atlanta Task Force is governed by a 21 member
                    Board of Directors chaired by Robert S. Cramer, Jr. The
                    Executive Director of the Task Force is Anita Beaty. The
                    books and records are located at 363 Georgia Avenue, SE,
                    Atlanta, Georgia.


                    The audit objectives were to determine if Metro Atlanta
 Audit objectives   Task Force for the Homeless administered its Innovative
                    Homeless and Supportive Housing Programs in an efficient,
                    effective and economical manner, and followed applicable
                    laws, regulations, and policies.

                    To accomplish the objectives, we tested program activities
 Audit scope and    for compliance with program requirements, interviewed
 methodology        appropriate HUD staff and Task Force officials, and
                    reviewed HUD and Task Force records related to the IHP
                    and SHP grants. We also reviewed various disbursements
                    for eligibility, support, and proper allocation.

                    Our review methodology included a judgmental selection of
                    4 of the 19 IHP client files of subrecipients that received
                    funds under the 1995 IHP grant. Additionally, we examined
                    client files for 6 of the 16 SHP subrecipients. We
                    judgmentally selected and tested financial transactions for 6
                    of the 17 1994 IHP draw requests and 10 of the 48 1995
                    IHP draw requests. We also tested 3 months of SHP
                    administrative draw requests and 5 months of SHP program
                    draw requests.

                    Further, we conducted site visits at four IHP and five SHP
                    subrecipients to determine whether the subrecipients
                    provided services pursuant to the contracts executed with
                    MATFH.

                    Our audit covered the period April 1, 1994, through
                    December 31, 1997. However, we extended the audit
                    period as necessary. We performed the audit field work
                    between March and May 1998. We conducted the audit in
                    accordance with generally accepted government auditing
                    standards for performance audits.




98-AT-251-1009          Page 2
                                                                                         Finding 1


      Innovative Homeless Program Was Not
            Effectively Administered
Metro Atlanta Task Force did not effectively administer its 1994 and 1995 Innovative Homeless
Program for which it received over $1.9 million in HUD funding. MATFH did not: (1)
adequately document payments to subrecipients; (2) ensure that the 1995 IHP subrecipients
properly determined client eligibility; (3) maintain sufficient records to demonstrate that clients
were served as proposed in its grant application; (4) require the subrecipients to submit audits;
and (5) close out its 1995 IHP program as required. This occurred because the Task Force did
not believe HUD’s documentation requirements applied to the grant program, and did not enforce
the terms of the subrecipient contracts. Consequently, we identified $1,243,854 of unsupported
costs and $6,607 of ineligible costs charged to the 1994 and 1995 IHP grants. The Task Force
could not measure its grant performance, and we were not assured that the resources were
assisting the homeless persons intended to be served by the program.


                                      Title 24 of the Code of Federal Regulations (CFR), Part 84,
 Criteria                             Subpart C, paragraph 84.21 (b)(3), requires the recipient’s
                                      financial management system to provide for effective
                                      control over and accountability for all funds, property and
                                      other assets.

                                      The Task Force did not maintain adequate documentation
 Inadequate documentation             to support the 1994 and 1995 IHP funds drawn down.
 to support payments to               Specifically, MATFH drew down $997,500 in 1994 IHP
 subrecipients                        grant funds. However, MATFH generally did not relate the
                                      draws to specific supporting documentation. Similarly,
                                      MATFH drew down $991,931 in 1995 IHP funds and did
                                      relate five of the ten request vouchers reviewed to specific
                                      supporting documentation. Consequently, we questioned
                                      $991,978 of 1994 IHP funds and $258,483 of 1995 IHP
                                      funds.

                                      The 1994 IHP Payments Were Not Properly Supported

                                      The Task Force drew down $997,500 from its 1994 IHP
                                      grant, but did not relate the funds to specific supporting
                                      documentation. We judgmentally selected six draw requests
                                      totaling $391,445, or 39 percent, to verify the supporting
                                      documentation. However, MATFH only provided limited
                                      documentation for one draw request of $150,000. We
                                      found that $5,522 of the request was supported, and
                                      $144,478 was unsupported. MATFH did



                                               Page 3                               98-AT-251-1009
Finding 1

                 not provide documentation to support the other five draw
                 requests. MATFH officials stated that they drew down the
                 funds in advance and did not relate them to specific
                 supporting documentation. As a result, $991,978 of the
                 1994 IHP grant remained unsupported.

                 Since MATFH’s files were not adequate to support the IHP
                 costs, we inventoried the files for all of the 1994 IHP
                 subrecipients. We wanted assurance that all documentation
                 was provided for our review. We determined that four
                 supporting documentation files and 12 contract files were
                 missing for its subrecipients.

                 The 1995 IHP Payments Were Not Properly Supported

                 The Task Force drew down $991,931 of its 1995 IHP
                 grant. The draw request generally included costs for several
                 different IHP subrecipients. We judgmentally selected ten
                 request vouchers to verify the supporting documentation.
                 Based on our review, the Task Force could not support
                 $84,558.     In addition, we reviewed the supporting
                 documentation for payments made to four subrecipients.
                 The subrecipients did not maintain adequate documentation
                 to establish client eligibility and/or did not service the
                 number of clients proposed. Therefore, $167,318 of the
                 subrecipients’ grant payments were unsupported.

                 We also reviewed $28,762 or 61 percent of the 1995
                 administrative charges totaling $47,500. We selected the
                 timesheets from October 1995 through May 1996 for four
                 of the five MATFH employees whose salaries were charged
                 to the program.       Our review found that MATFH
                 overcharged $6,607 in administrative costs to the program.

                 Because of personnel turnover, we could not make an
                 accurate assessment of the reason for the improper
                 payments. As a result, $251,876 of unsupported costs and
                 $6,607 of ineligible costs were charged to the 1995 IHP
                 grant.




98-AT-251-1009       Page 4
                                                                                   Finding 1

The Task Force did not maint   The Task Force did not maintain documentation to evidence
 Site visits performed at
                               the number of persons served under the program.
 subrecipients
                               Therefore, we judgmentally selected and conducted site
                               visits at 4 of the 19 subrecipients. We reviewed the
                               subrecipients to determine if clients were part of the specific
                               population targeted in the approved application.

                               Georgia State Office of Community Planning and
                               Development issued Circular Number IV-CPD-96-03, dated
                               October 19, 1995, that requires adequate documentation on
                               the eligibility of persons to be served by HUD homeless
                               assistance programs. The homeless funding recipients are
                               required to intake information from the clients and verify the
                               clients’ homeless status.      Examples include obtaining
                               written verifications from clients that came from emergency
                               shelters, social services agencies, and transitional housing
                               facilities. In cases where persons are at imminent risk of
                               homelessness, because they face immediate eviction, and do
                               not have sufficient resources to find replacement housing,
                               there should be evidence of eviction proceedings and
                               information regarding income of clients. If the recipient is
                               unable to verify the client’s homeless status, then a short
                               written statement about the client’s living place should have
                               been prepared, with the client’s signature and date on it.

                               The subrecipient’s contract with the Task Force states that
                               the subrecipient shall submit by the 1st day of each month a
                               progress report to the grantee.

                               Eligibility of Homeless Clients Was Not Verified

                               Our review included files of clients that entered the program
                               after the October 19, 1995, Circular issue date. The
                               subrecipients did not adequately verify the eligibility of
                               clients served. Specifically, one subrecipient admitted
                               clients into the program without documenting pertinent
                               client information such as living conditions, income
                               information and personal contacts on the intake forms and
                               verifying the information.        Instead, the subrecipient
                               documented basic client information such as name, date of
                               birth, and social security number on index cards.
                               Information regarding the type of services provided to the
                               clients was not obtained or documented. The other three




                                          Page 5                              98-AT-251-1009
Finding 1

                 subrecipients obtained client information on intake forms,
                 but did not verify pertinent information on the form to
                 establish client eligibility. The subrecipients did not verify
                 the client’s income and prior living situation.

                 MATFH officials also stated that they verified the eligibility
                 of clients they referred to the subrecipients. However, we
                 found that MATFH did nothing more than intake limited
                 data on the hotline and refer the clients to subrecipients.
                 We did not find any documentation at the Task Force to
                 support the eligibility of clients.

                 Number of Homeless Clients Served Was Not Documented

                 During the site visits, we found that the subrecipients did
                 not always serve the number of clients proposed in the grant
                 applications. Two of the subrecipients we visited did serve
                 the proposed number of clients. However, one of the
                 remaining two subrecipients did not serve its proposed
                 number of clients and the other subrecipient did not
                 maintain adequate records to evidence the number of clients
                 it served.

                 MATFH’s records should have included this type of
                 documentation but did not. Although stipulated in the
                 contracts with the IHP subrecipients, MATFH did not
                 require the subrecipients to submit monthly progress
                 reports. The reports would have documented the number of
                 clients served. Our review of MATFH’s report files showed
                 that only 4 of the 19 IHP subrecipients submitted from one
                 to three monthly reports.

                 In September 1995, the HUD Georgia State Office of
                 Community Planning and Development Branch conducted a
                 monitoring review of the Task Force’s 1995 IHP homeless
                 grant subrecipients. The HUD office concluded that the
                 Task Force failed to document and record the number of
                 homeless clients served, and did not document the eligibility
                 of clients served. The HUD office also stated that this
                 situation existed from the start of the program (and
                 presently continues). We noted that as of our review, the
                 Task Force did not record the number of homeless clients
                 served or document the eligibility of clients served. In other
                 words, they ignored HUD.




98-AT-251-1009        Page 6
                                                                              Finding 1

                           The Task Force did not obtain all the audits for its IHP
Audits for subrecipients
                           subrecipients as required. Office of Management and
were not obtained
                           Budget (OMB) Circular A-133, Section 7, requires
                           recipients to ensure that subrecipients obtain audits annually
                           or not less frequently than every 2 years. Section 5(a)
                           requires a recipient that receives a federal award and
                           provides $25,000 or more of it during its fiscal year to a
                           subrecipient to ensure that the non-profit institution
                           subrecipients that receive $25,000 or more have met the
                           audit requirements. Audits were due from seven of the
                           Task Force’s 1994 subrecipients and one of its 1995
                           subrecipients.

                           The Task Force’s 1995 IHP grant completion date was
Final annual close-out
                           September 30, 1997. The close-out report should have
report for the 1995 IHP
                           been submitted to HUD by December 29, 1997. As of June
grant was not completed
                           18, 1998, the HUD Program Office had not received a final
                           annual close-out report from MATFH.

                           Title 24 CFR, Part 84, Subpart D, requires recipients to
                           submit all financial, performance, and other reports as
                           required by the terms and conditions of the award within 90
                           days after the date of completion of the award.

                           The HUD Office requested the report in a letter dated
                           January 14, 1998. MATFH officials stated that they
                           submitted the report to the HUD Georgia State Office.
                           However, they could not locate a copy of the report for our
                           review.


                           Excerpts from the Task Force’s comments on our draft
 Auditee comments          findings follow. Appendix B contains the complete text of
                           the comments.

                           The Task Force generally disagreed with the finding.
                           MATFH officials said that the Office of Inspector General
                           auditors misstated the Task Force procedures for the 1994
                           and 1995 IHP grants. The Task Force manual procedures
                           pertains to its SHP grant only. The Task Force stated they
                           drew the IHP funds from HUD in advance and documented
                           total payments for each subrecipient, but did not match
                           documentation to draw requests.




                                      Page 7                              98-AT-251-1009
Finding 1

                       The Task Force never told subrecipients not to document
                       client eligibility but that the Georgia State Office accepted
                       the Task Force’s hotline database as documentation to
                       support the eligibility of clients. Also, the Task Force
                       submitted documentation for administrative charges to the
                       Georgia State Office who accepted the documentation.
                       The Task Force furnished the auditors with the audits for
                       the Atlanta Union Mission and the Task Force for the
                       Homeless and was unaware of any other requests made by
                       the auditors. In addition, all IHP files were provided by the
                       Task Force.

                       The Task Force stated that the 1995 IHP close-out report
                       was not due because over $5,000 of funds remains to be
                       drawn down.



                       Although the Task Force’s procedures manual contained
   OIG evaluation of   criteria relating to the IHP grant, according to the MATFH
   auditee comments    the manual was for the SHP grant. Based on the Task
                       Force’s comments, we made revisions to the finding criteria.

                       The Task Force did not demonstrate that it maintained
                       effective control over the expenditures of federal funds
                       because it did not maintain sufficient documentation as
                       required by HUD.

                       The HUD Georgia State Office staff stated that the
                       requirements for documentation of client eligibility prior to
                       the October 19, 1995, Circular were loose. However, the
                       HUD Office pointed out that it advised the Task Force of
                       documentation deficiencies in its 1995 and 1996 monitoring
                       letters. The Georgia State Office also pointed out that it
                       issued a HUD Circular in October 1995 that clarified the
                       types of documentation required to establish client
                       eligibility. The Office provided that this Circular was
                       applicable to all homeless programs. During our site visits,
                       we reviewed files of clients that entered the program after
                       the October 19, 1995, Circular issue date and found that the
                       Circular was not adhered to.




98-AT-251-1009             Page 8
                                                                    Finding 1

                  The Georgia State Office did not review or accept
                  documentation from the Task Force that supported the
                  administrative charges. As noted in Finding 1, the Task
                  Force did not maintain sufficient documentation to support
                  1995 IHP administrative charges.

                  We requested all audit reports from the Task Force’s HUD
                  Program Director. We also discussed the missing files with
                  the Task Force’s Director of Operations. The Director
                  stated that the files had been misplaced because so many
                  people had access to them but that they could be located in
                  time.

                  The Georgia State Office established the 1995 IHP grant
                  completion date as September 30, 1997. Therefore, the
                  close-out report was due December 29, 1997, as stated in
                  the finding. Although the Task Force contends that it still
                  has a balance of over $5,000 to draw down from the 1995
                  IHP grant, the Georgia State Office has flagged the funds to
                  be deobligated. Thus, the remaining 1995 IHP funds are
                  not available to the Task Force.



Recommendations   We recommend that you require the Task Force to:

                  1A.    Provide detailed support for $1,243,854 of
                         unsupported program costs charged to the 1994 and
                         1995 grants, or repay any unsupported amount to
                         the Line of Credit Control System from non-federal
                         sources.

                  1B.    Reimburse the U. S. Treasury $6,607 of ineligible
                         administrative costs charged to the 1995 IHP grant
                         from non-federal sources.

                  1C.    Provide written documentation to support the
                         eligibility of clients served during the period the
                         1994 and 1995 IHP funds were received.

                  1D.    Provide documentation to show the number of
                         homeless clients served and the effectiveness of the
                         use of IHP funds drawn from the U.S. Treasury’s
                         Line of Credit Control System.




                            Page 9                             98-AT-251-1009
Finding 1

                 1E.     Provide evidence that the subrecipients obtained the
                         required independent audits.

                 1F.     Provide HUD the final annual close-out report for
                         the 1995 IHP grant.




98-AT-251-1009         Page 10
                                                                                          Finding 2


   Accounting Records Needed Improvement
Metro Atlanta Task Force for the Homeless accounting records needed improvement. The Task
Force did not maintain proper accounting records for its $12.4 million received in Supportive
Housing Program funds. In addition, MATFH’s costs were not properly documented or
supported, and reimbursements to subrecipients were untimely. This prevented MATFH’s ability
to disclose current, accurate, and complete financial information related to its Supportive Housing
Program. Consequently, MATFH reimbursed subrecipients $66,427 in unsupported costs, paid
$760 of ineligible program costs, and charged $8,824 of ineligible administrative costs from the
SHP grant. This occurred because MATFH incurred high turnover in its fiscal department and
did not have appropriate staff in place to effectively administer its fiscal operations. As a result,
we could not obtain reasonable assurance of the accountability of the SHP funds.


                                      The Task Force’s accounting system was inadequate.
 Accounting system was                MATFH’s accounting system did not adequately track SHP
 inadequate                           expenditures. Also, administrative costs records were
                                      inconsistent, and accounting records contained inaccurate
                                      and incomplete information.

                                      Title 24 CFR, Part 84.21(b)(1) states that a recipient’s
                                      financial management system shall: (1) provide accurate,
                                      current, and complete disclosure of the financial results of
                                      each federally sponsored project or program, and (2)
                                      maintain effective control over and accountability for all
                                      funds, property, and other assets.        Recipients shall
                                      adequately safeguard all such assets and assure they are
                                      used solely for authorized purposes.

                                      Expenses Were Inadequately Tracked

                                      When the Task Force was awarded its SHP grant, HUD
                                      established and set up budget line items in its Line of Credit
                                      Control System. However, MATFH did not establish
                                      general ledger accounts to record and track SHP grant costs
                                      by budget line item for each subrecipient under its new
                                      accounting system. Instead, MATFH charged all costs to a
                                      general fund account for each subrecipient. MATFH
                                      tracked its administrative costs and the subrecipients’
                                      program expenditures on individual spreadsheets. The
                                      subrecipient spreadsheets outlined the budget line items
                                      approved by HUD and the amounts drawn down against
                                      each line item. It further reflected




                                               Page 11                                98-AT-251-1009
Finding 2

                 total expenditures for year-to-date and total budget
                 allocations. Although MATFH’s current general ledger did
                 not record and track SHP grant costs by budget line item,
                 the spreadsheets maintained tracked such information.
                 However, the spreadsheets were not part of MATFH’s
                 official accounting records. Our review of the spreadsheets
                 found that the spreadsheets contained inaccurate
                 information and were not complete. For example, a
                 subrecipient’s total operating expenditures were recorded as
                 $14,942 but the actual expenditures were $15,052.
                 Additionally, another subrecipient’s spreadsheet did not
                 account for all of the draw requests made. Therefore, the
                 accounting records did not accurately reflect a true and
                 complete accounting of the subrecipient’s grant position.

                 The Executive Director stated that since the inception of the
                 programs, there has been significant staff turnover. She
                 also said that MATFH changed accounting software.

                 Administrative Costs Records Were Inconsistent

                 The Task Force’s SHP administrative costs reported on its
                 spreadsheets were not consistent with the general ledger
                 amounts. Generally, the spreadsheet amounts exceeded the
                 general ledger amounts. For example, in January, July, and
                 November 1997, the spreadsheets reflected $1,021 charged
                 for the Director of Operations’ salary, but the general ledger
                 only reflected $729 for the same periods. However, based
                 on the hours reflected on her timesheets, we determined the
                 salary rate was between $612 and $700.

                 Additionally, MATFH’s 1997 spreadsheet reflected
                 budgeted salary costs of $25,000, or 35 percent, for its
                 Accounting Assistant. The general ledger for the same
                 months did not account for any of her salary. However, the
                 timesheets showed that in January 1997 she spent 100
                 percent of her time on SHP activities, and 45 percent of her
                 time in July and November 1997 on the activities.

                 Furthermore, we determined that the SHP general ledger
                 administrative account included charges for an employee
                 that were not included in the budget to HUD or on
                 MATFH’s spreadsheet of administrative costs.




98-AT-251-1009        Page 12
                                                   Finding 2

MATFH officials could not tell us which set of records
reflected the correct financial information or could not
provide the necessary information to perform an accurate
analysis of the records. Therefore, we were not assured of
the amounts charged for SHP administrative costs.

Accounting Records Were Inaccurate and Incomplete

The Task Force’s accounting records contained inaccurate
and incomplete information. Examples of inaccurate and
incomplete records are presented below.

   •   The ending SHP account balances from fiscal year
       1996 were not brought forward as beginning
       balances in the 1997 general ledger. Thus, the 1997
       SHP account balances were not all inclusive.

   •   MATFH used its SHP administrative account to
       record administrative reimbursements and at the
       same time to account for administrative costs
       incurred but not yet paid. This caused the account
       balance to be distorted.       MATFH needed to
       establish a separate account to reflect administrative
       costs earned but not yet paid.

   •   MATFH incorrectly classified a SHP administrative
       draw totaling $2,454. The amount was posted to
       the HUD Supportive Housing Grant account, which
       captured all SHP draws for the subrecipients. The
       amount should have been posted to the HUD
       Supportive Housing Administrative account.

   •   In tracing the draw amounts to MATFH’s general
       ledger, we noted that MATFH had drawn down
       funds against the budget line items of a subrecipient
       but the supporting documentation for the draw was
       for a different subrecipient.

The Task Force is in the process of revising their accounting
system structure to include general ledger accounts to
record and track SHP grant costs by budget line item. Also,
the Task Force has established the necessary receivable
account to track administrative costs incurred but not yet
paid.



         Page 13                              98-AT-251-1009
Finding 2

                          The Task Force did not obtain adequate supporting
 Program costs were not   documentation from its subrecipients for program costs
 properly supported       paid. As of March 1998, MATFH had drawn down
                          $3,056,601 in SHP funds on behalf of the subrecipients.
                          We reviewed $400,788, or 13 percent, of the SHP grant
                          drawdowns. We determined that $67,187 of the $400,788
                          was not adequately supported and/or ineligible.

                          Specifically, MATFH reimbursed subrecipients $66,427 for
                          program costs that were unsupported and $760 for program
                          costs that were not eligible. MATFH did not obtain
                          appropriate supporting documentation such as employee
                          timesheets, invoices, and/or copies of checks before
                          reimbursing subrecipients. MATFH officials stated that
                          they believed the documentation they maintained on file was
                          sufficient, because HUD officials told the subrecipients that
                          the documentation submitted was sufficient. We confirmed
                          the information with HUD. The Community Planning and
                          Development Representative stated that he did not recall
                          informing subrecipients that their documentation was
                          sufficient.

                          The following table depicts the results of the SHP program
                          costs reviewed.

                            Date of
                             SHP                                                      Total
                             Draw         Draw      Unsupported      Ineligible     Questioned
                            Request      Amount        Costs           Costs          Costs

                            04/96        $ 73,743       $      647        $     0       $      647
                            09/96          66,658              320              0              320
                            02/97          48,345            2,831            175            3,006
                            07/97         122,304           58,068            585           58,653
                            12/97          89,738            4,561              0            4,561

                            Totals       $400,788       $66,427           $760          $67,187

                          During our review, MATFH officials prepared a letter for
                          each subrecipient requesting supporting documentation for
                          the costs identified as unsupported.




98-AT-251-1009                 Page 14
                                                                              Finding 2

                           The Task Force did not support its salary distribution. As
Documentation for          of March 9, 1998, MATFH had drawn down $259,152 in
administrative costs was   administrative funds. We judgmentally selected three SHP
insufficient               administrative draw requests for review. The draws totaled
                           $106,644, or 40 percent, of the total funds. MATFH’s
                           individual employee timesheets did not always support the
                           salary percentage charged to the SHP program.

                           OMB Circular A-122, Cost Principles for Non-Profit
                           Organizations, Attachment B, paragraph (6)(l)(1) states that
                           charges to awards for salaries and wages, whether treated as
                           direct or indirect costs, will be based on documented
                           payrolls approved by responsible official(s) of the
                           organization. The distribution of salaries and wages must
                           be supported by personnel activity reports except when a
                           substitute system has been approved in writing by the
                           cognizant agency. The reports must reflect an after-the-fact
                           determination of the actual activity of each employee.
                           Budget estimates (i.e., estimates determined before the
                           services are performed) do not qualify as support for
                           charges to awards.

                           MATFH charged $1,021 monthly, or 35 percent, of the
                           Director of Operations’ salary to the SHP account during
                           1997. However, the timesheets for January, July, and
                           November 1997 did not support the 35 percent MATFH
                           charged. Instead, the timesheets reflected a rate between 21
                           and 24 percent of her time spent on the SHP activities. The
                           salary amounts charged to the program should have been
                           $642 for January, $612 for July, and $700 for November.
                           Therefore, total ineligible costs of $1,109 were charged for
                           the Director of Operations’ salary.

                           Additionally, MATFH overcharged the SHP account $7,715
                           in contract costs for a consultant. From April 1996 through
                           December 1996, MATFH charged the consultant’s total
                           monthly salary of $4,153 to SHP activities even though he
                           spent time on other unrelated activities. The consultant was
                           primarily responsible for assisting in project monitoring and
                           troubleshooting subrecipient contract performance.




                                    Page 15                              98-AT-251-1009
Finding 2

                       MATFH’s Executive Director stated that she felt that the
                       timesheets supported the amounts charged to the program
                       because the amount of time billed to the program was less
                       than the actual amount of time spent on the program. She
                       said that the percentages were based on the minimum
                       amount that could be charged, which was five percent of the
                       total grant amount. She also stated the Task Force has
                       spent far more time administering the program than they can
                       bill for.

 Subrecipients were    The Task Force did not reimburse subrecipients in a timely
 reimbursed untimely   manner. 24 CFR, Part 84, Subpart C, paragraph 84.22
                       requires grantees to establish a payment method that shall
                       minimize the time elapsing between the transfer of funds
                       from the United States Treasury and the issuance or
                       redemption of checks, warrants, or payment by other means
                       by the recipients.

                       In one case, MATFH did not reimburse the subrecipient
                       until 29 days after the funds were electronically credited to
                       its account. Specifically, $9,130 was credited to the
                       MATFH’s operating account on January 2, 1998.
                       However, MATFH did not cut a check to reimburse the
                       subrecipient until January 31, 1998. In another case,
                       MATFH had $19,285 credited to its operating account on
                       January 7, 1998, but did not reimburse the subrecipient until
                       January 31, 1998, 24 days later.

                       In a March 11, 1997, letter to the Task Force, HUD
                       officials recommended that cash management procedures be
                       established to meet the standards for fund control. The
                       HUD office had received letters from two of the SHP
                       subrecipients regarding late reimbursement of payments
                       from the Task Force. As of our review, the untimely
                       payments still continued.

                       MATFH’s Executive Director stated that sometimes
                       payments to subrecipients were delayed because reports
                       were due from the subrecipients. Also, she said that two
                       signatories were not always present to sign the check, but
                       usually not for more than one day.




98-AT-251-1009             Page 16
                                                                       Finding 2

                     Excerpts from the Task Force’s comments on our draft
                     findings follow. Appendix B contains the complete text of
Auditee comments     the comments.

                     The Task Force generally disagreed with the finding. The
                     Task Force made the following comments:

                        •   The Task Force established general ledger accounts
                            to record and track SHP grant costs by subrecipient
                            line items and that those accounts were reviewed
                            and approved by the Office of Inspector General’s
                            staff in a preliminary review of their accounting
                            system and by the HUD Program Financial Staff
                            person.      The Task Force contended that the
                            spreadsheets were set up and maintained as part of
                            their official accounting records.

                        •   The Task Force’s 1996 ending SHP account
                            balances had not been brought forward as beginning
                            balances in its 1997 general ledger because the Task
                            Force was still undergoing its 1996 audit at the time
                            we began our audit. Thus, such information would
                            not have been available until the audit was complete.

                        •   The Task Force provided substantial additional
                            documentation as well as copies of letters they sent
                            to subrecipients as it related to program costs not
                            being properly supported. The Task Force contends
                            that its employee timesheets more than support the
                            charges it made. According to the Task Force, they
                            over documented time attributed to the SHP
                            contract.

                        •   The Task Force received HUD approval for a 30-
                            day turnaround for reimbursement procedures.



 OIG evaluation of   The purpose of the Office of Inspector General’s 1997
 auditee comments    accounting system evaluation was to provide reasonable
                     assurance that the Task Force had systems and controls in
                     place to account for the receipt and disbursement of grant
                     funds at the time of the review. Thus, the evaluation was
                     not an approval of its accounting system. Also, the HUD




                              Page 17                             98-AT-251-1009
Finding 2

                   Program Office provided technical assistance related to the
                   SHP program and guidance on how their official accounting
                   records needed to reflect their SHP expenditures.

                   Although the Task Force contends that the accounting
                   information was not current because the 1996 audit was not
                   complete, the report still was not issued at the completion
                   of our review. The accounting records related to the 1996
                   activity should have been closed and accurately reflected in
                   1998.

                   We reviewed all documentation the Task Force provided as
                   support for its SHP program costs and the documentation
                   was not sufficient to fully resolve the issue. The HUD
                   Program Office officials said they did not approve the
                   accounting system or the 30-day turnaround for
                   reimbursement.



 Recommendations   We recommend that you require the Task Force to:

                   2A.     Establish fund accounts in its general ledger to track
                           the receipt and use of SHP subrecipient grant funds
                           by the HUD approved budget line item.

                   2B.     Establish financial records that provide a full and
                           accurate disclosure of the SHP administrative funds
                           drawn down from the U.S. Treasury’s Line of Credit
                           Control System.

                   2C.     Provide detailed documentation to support
                           administrative costs drawn down from each SHP
                           subrecipient Line of Credit.

                   2D.     Establish written internal control procedures for
                           staff to follow in the event of a staff turnover, or a
                           change in accounting software.

                   2E.     Provide adequate support for $66,427 of
                           subrecipient program costs that were unsupported
                           or repay any unsupported costs to the SHP account
                           Line of Credit Control System.




98-AT-251-1009           Page 18
                                                Finding 2

2F.   Reimburse the SHP account Line of Credit Control
      System for ineligible subrecipient program costs of
      $760.

2G.   Reimburse the SHP account Line of Credit Control
      System for ineligible administrative costs of $8,824
      to the appropriate subrecipients.

2H.   Implement its policies and procedures for reviewing
      and approving requisitions for payments from SHP
      subrecipients.

2I.   Implement cash management procedures that will
      ensure that reimbursements to SHP subrecipients are
      issued in a reasonable timeframe after receipt of
      Treasury funds.

2J.   Take other appropriate action, as needed, including
      terminating the SHP grant awards.




        Page 19                            98-AT-251-1009
Finding 2




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98-AT-251-1009                Page 20
                                                                                        Finding 3




     Inadequate Monitoring of Subrecipients
Metro Atlanta Task Force for the Homeless did not adequately monitor the subrecipients under its
Supportive Housing Program. Specifically, the Task Force did not: (1) perform monitoring visits
in accordance with the terms of its contract; (2) monitor the submission of Annual Performance
Reports; and (3) did not require subrecipients to document client eligibility, or obtain financial
audits. MATFH did not enforce its procedures for subrecipients. As a result, the Task Force
could not demonstrate the impact SHP funding had on the homeless population or whether the
subrecipients served the number of individuals proposed in its grant applications.


                                     Title 24 of the Code of Federal Regulations, Part 84.51 (a),
 Criteria                            states that recipients are responsible for managing and
                                     monitoring each project, program, subaward, function or
                                     activity supported by the award.

                                     The Task Force subrecipient monitoring procedures states
                                     that the Task Force will conduct no less than two (2) on-site
                                     visits of subrecipients within the grant year. The same
                                     procedures are contained in the contracts executed with the
                                     subrecipients. The use of the on-site monitoring visit will be
                                     the Task Force’s primary form of compliance management.
                                     When conducting on-site monitoring visits, the monitoring
                                     procedures require a review of the subrecipient files for
                                     required documentation and to verify the accuracy of the
                                     information provided; interview members of the subrecipient
                                     staff to discuss performance; and interview clients to assess
                                     the level of service, homeless status, and qualification as a
                                     member of the target group.

                                     In addition, the monitoring procedures state the subrecipient
                                     will be reviewed to: (1) ensure that the services are rendered
                                     to the target population, (2) determine the overall progress
                                     of the program and the extent to which goals and objectives
                                     are met, and (3) ensure compliance with other requirements.

                                     The Task Force procedures for subrecipient agencies
                                     require all subrecipients provide adequate documentation to
                                     verify whether clients are a part of the specific population
                                     targeted in the approved application.        Therefore, all
                                     subrecipients of the Task Force must verify that the clients
                                     served under a particular grant are homeless and that total
                                     income is below the median low income range. The

                                              Page 21                               98-AT-251-1009
Finding 3


                         subrecipients are required to submit annual progress reports
                         45 days after the end of the grant year.

                         The Task Force did not follow its monitoring procedures.
 Monitoring procedures
                         Specifically, MATFH did not perform timely on-site
 were not followed
                         monitoring reviews of the subrecipients, and when reviews
                         were performed the scope of the reviews was not adequate.
                         In addition, MATFH did not effectively monitor the
                         submission of the annual performance reports.

                         On-Site Monitoring Procedures Were Not Followed

                         We judgmentally selected 6 of the 16 subrecipients and
                         reviewed MATFH’s monitoring efforts. We found that the
                         Task Force did not perform the required annual on-site
                         visits for the subrecipients. As shown in the table below,
                         MATFH only performed one on-site visit for four of the six
                         subrecipients reviewed. MATFH did not perform any on-
                         site visits for the remaining two subrecipients.

                                 Project                   Number       Number
                                 Number        Operating     of           of
                                   of            Start     Reviews      Reviews
                               Subrecipient      Date       Due        Conducted

                            GA06A15-1035       11/1/96        2             1
                            GA06G15-1035        1/1/96        4             1
                            GA06H15-1035        3/1/96        4             1
                            GA06K15-1035        1/1/97        2             0
                            GA06N15-1035        1/1/96        4             0
                            GA06X15-1035        3/1/96        4             1

                         Although MATFH performed on-site monitoring visits to
                         some of its SHP subrecipients, we found that the work
                         performed during the visits was not adequate. The
                         monitoring checklist completed by MATFH’s staff was too
                         general.     Specifically, the reviews did not document
                         sufficient information to support the responses provided on
                         the checklist. Also, the reviews did not document how
                         many files were reviewed to obtain reasonable assurance
                         that the subrecipient was providing services pursuant to its
                         contract.




98-AT-251-1009               Page 22
                                                Finding 3


Furthermore, the review did not document the verification
of the number of persons the subrecipient reported as being
served in its Annual Performance Report. This was
important considering MATFH failed to require the
subrecipients to submit progress reports and did not verify
the numbers reported in the Annual Performance Reports.

According to the Task Force HUD Program Director, she
reviewed client files while on site and conducted interviews
with the clients to determine what services they had been
provided. However, the reviews and interviews were not
documented. Thus, we could not be assured that this work
was actually completed. Also, she stated that she did not
know that she needed to review subrecipients’ file
documentation to verify that the number of persons
reported as being served were in fact provided services.

Off-Site Monitoring Procedures Were Not Followed

MATFH did not follow its off-site monitoring procedures.
MATFH did not effectively monitor to obtain the Annual
Performance Reports in a timely manner.

We conducted a review to determine whether the Annual
Performance Reports were submitted as required for the
same six subrecipients identified above. We found that
Annual Performance Reports were not submitted timely to
MATFH. For example, a subrecipient’s report was due on
December 15, 1997, 45 days after its October 31, 1997,
grant year. However, the report was dated March 19, 1998,
90 days after the due date. The report was not date
stamped to identify the date it was actually received by
MATFH.

Also, the Annual Performance Report for another
subrecipient was due on February 15, 1998, although as of
May 1998, the report had not been submitted to the Task
Force.     Furthermore, another subrecipient’s Annual
Performance Report was due on February 15, 1998. During
a May 1998 site visit at the subrecipient, OIG auditors
inquired about the overdue report. The report was provided
to the Task Force official at that time. The report was
dated May 7, 1998, which was 82 days late. We found no
evidence that MATFH staff followed up with these
subrecipients to obtain the reports in a timely manner.

         Page 23                             98-AT-251-1009
Finding 3


                            Our review of the Annual Performance Report statistics
                            revealed that the subrecipients were generally progressing
                            well towards meeting their goals to serve a certain number
                            of homeless individuals and/or families, with the exception
                            of one. The subrecipient had proposed to provide services
                            to 1,400 homeless individuals but reported that it had only
                            served 763 individuals by the end of its second grant year.
                            MATFH did not address this potential problem in its
                            November 26, 1997, monitoring visit.

                            MATFH’s Executive Director stated that her staff
                            developed a program database system that would allow
                            each subrecipient to report progress data on the computer.
                            However, the Task Force was overruled by the Georgia
                            HUD Program Office.           According to the Executive
                            Director, the system would have prevented the untimely
                            submission of Annual Performance Reports and would have
                            served as a monitoring mechanism. The HUD officials
                            stated that the Task Force could not require the
                            subrecipients to use the database system developed.

                            The Task Force did not maintain documentation to
 Site visits performed at   demonstrate the progress of each subrecipient. Therefore,
 subrecipients              we judgmentally selected and performed site visits at five
                            subrecipients. We reviewed the subrecipients to determine
                            whether they were providing services pursuant to its
                            contracts with the Task Force.

                            We found that three of the subrecipients were not properly
                            establishing client eligibility in accordance with MATFH and
                            HUD procedures. Specifically, the three subrecipients did
                            not obtain written verification of prior living situations
                            and/or verifications of income. One subrecipient merely
                            obtained the verification of homelessness form with the
                            client’s signature without obtaining written verification of
                            the client’s prior living situation.          The other two
                            subrecipients generally obtained proper written verification
                            to establish whether the client was in fact homeless, but had
                            not documented verification of the client’s income, as
                            required by MATFH procedures.               Without adequate
                            documentation, we cannot be assured that the program and
                            resources the subrecipients provided were reaching the
                            homeless persons intended to be served by the program.




98-AT-251-1009                  Page 24
                                                                           Finding 3



                         We determined that the five subrecipients generally
                         maintained documentation to support that they served the
                         number of clients reported in its Annual Performance
                         Reports. As for the services provided, we found that four
                         of the five subrecipients maintained appropriate
                         documentation to evidence the type services provided to the
                         clients. The services documented by each of these
                         subrecipients were in accordance with the services proposed
                         in the contracts with the Task Force. The remaining
                         subrecipient did not document the services it provided to
                         the clients that entered its program.             Based on
                         documentation submitted in the subrecipient’s package for
                         reimbursement, it was obvious that costs were incurred for
                         supportive services. However, we could not identify the
                         extent of services that were provided to each client.

                         The Task Force did not obtain audits of its subrecipients
Financial audits of
                         under the SHP program as required and did not establish
subrecipients were not
                         procedures for obtaining the audits. The Task Force
obtained
                         budgeted $40,000 for the financial audit of the
                         subrecipients.

                         OMB Circular A-133, Section 5(a) requires a recipient that
                         receives a federal award and provides $25,000 or more of it
                         during its fiscal year to a subrecipient to ensure that the
                         non-profit institution subrecipients that receive $25,000 or
                         more have met the audit requirements. Section 7 states that
                         the audits should be performed annually but not less than
                         every two years. Subpart A, Section 105, defines an auditor
                         as a public accountant which meets the general standards
                         specified in generally accepted government auditing
                         standards. The term auditor does not include internal
                         auditors of non-profit organizations.

                         The budget stipulated that MATFH would provide an audit
                         for the subrecipients that needed assistance in obtaining the
                         required audit. However, the money budgeted for such
                         costs was not used for the audits. MATFH did not obtain
                         or provide for any audits of the subrecipients since inception
                         of the grant agreements. The $259,152 MATFH drew
                         down in administrative funds was used to pay for
                         administrative salary costs, training, and equipment.




                                   Page 25                              98-AT-251-1009
Finding 3


                                              We judgmentally selected and reviewed the files for six
                                              subrecipients that had been operating for 2 years at the time
                                              of our review and received at least $25,000 of the federal
                                              grant award during the 1996 grant year. The following
                                              table illustrates the results of our review:

                                                                Operating        Federal        Current      Last
                                          Project Number          Start           Funds          Audit       Audit
                                                                  Date           Awarded         Due1       Obtained

                                          GA06E15-1035            1/1/96           $129,769    12/ 31/96    12/31/94
                                          GA06F15-1035            2/1/96             76,185    09/30/96     09/30/94
                                          GA06G15-1035            1/1/96            112,284    09/30/96     09/30/95
                                          GA06N15-1035            1/1/96            196,370    12/31/96     12/31/94
                                          GA06T15-1035            2/1/96             44,672    12/31/96     12/31/94
                                          GA06X15-1035            3/1/96             66,532    12/31/96     12/31/96
                                                                                                            (not yet
                                                                                                            issued)

                                              The Executive Director stated that the HUD Program
                                              Office instructed them to hire a Certified Public Accountant
                                              to perform the audits and they did. However, the
                                              subrecipients did not want the Task Force’s accountant to
                                              perform its audits. Instead, the subrecipients wanted the
                                              Task Force to provide the funds to obtain the audits. The
                                              HUD Program Office addressed the issue in two memos to
                                              the Task Force dated October 23, 1997 and January 13,
                                              1998. HUD gave the Task Force two options regarding the
                                              audits for the subrecipients. The options included allowing
                                              the subrecipients to obtain an independent auditor or the
                                              Task Force could procure an independent auditor to
                                              conduct the audits. The HUD Program Office informed the
                                              Task Force to let the subrecipients select their own
                                              accountant and MATFH should be willing to provide the
                                              funds out of its administrative budget. The Executive
                                              Director stated that she refused to provide the funds to the
                                              subrecipients because MATFH hired an accountant to
                                              perform the audits.




1
    Determined based on the operating start dates and the period of the last audit obtained for each subrecipient.

98-AT-251-1009                                      Page 26
                                                                   Finding 3


                   We determined that MATFH could not have used the
                   Certified Public Accountant it hired to perform the audits
                   because the individual was an employee of the Task Force.
                   Thus, the individual was an internal auditor and not an
                   independent public accountant as required. Because the
                   Executive Director stated that the Task Force was incurring
                   more administrative costs than could be drawn down and all
                   funds drawn down were being used to cover employee
                   salary costs, the Task Force may not be in a position to
                   provide or pay the funds necessary to obtain the audits.


Auditee comments   Excerpts from the Task Force’s comments on our draft
                   findings follow. Appendix B contains the complete text of
                   the comments.

                   The Task Force generally disagreed with the finding. The
                   Task Force made the following comments:

                      •   The Task Force’s HUD Program Director reviewed
                          documentation to determine and monitor clients
                          served at subrecipient agencies, but that the
                          documentation was never required to be kept at its
                          site.

                      •   The Office of Inspector General confused the SHP
                          grant criteria with the IHP grant criteria because
                          they never required SHP program subrecipients to
                          submit quarterly progress reports. The Task Force
                          instead developed the computerized annual
                          performance report system which allowed for daily
                          intake and reporting that accumulated data. The
                          Task Force acknowledged that annual performance
                          reports were not being submitted timely and stated
                          that they are addressing the problem.

                      •   The Task Force’s Executive Director was misquoted
                          as it related to not requiring the SHP subrecipients
                          to submit quarterly progress reports because HUD
                          Program Office did not allow them to require the
                          subrecipients to use their computerized annual
                          performance report system.




                            Page 27                            98-AT-251-1009
Finding 3



                        •   The Task Force contends that they maintained
                            documentation to demonstrate the progress of each
                            subrecipient. However, they said the nature of that
                            documentation is in question. The Task Force said
                            that they were told by the HUD Program staff that
                            the documentation should be kept at subrecipient
                            sites.

                        •   The HUD Program staff made them relent on the
                            requirement to obtain audits of the SHP
                            subrecipients. The Task Force said they understood
                            they could use the Certified Public Accountant hired
                            for its fiscal office to audit the subrecipients and
                            provide technical assistance.


 OIG evaluation of   Although the Task Force stated that monitoring
 auditee comments    documentation and support to demonstrate the progress of
                     each subrecipient was not required to be kept at its site, the
                     documentation should have been maintained at its office to
                     support its monitoring efforts. The HUD Program Office
                     never told the Task Force that such documentation should
                     be kept at subrecipient sites.

                     The Accounting Procedures Manual used by the Task Force
                     was inconsistent as to which HUD program it applied to.
                     Therefore, we could not obtain clarification as to whether
                     the requirement that all subrecipients submit quarterly
                     progress reports applied to SHP subrecipients.

                     The Task Force contends they hired a Certified Public
                     Accountant for their fiscal office and understood they could
                     use the accountant to audit the subrecipients. The HUD
                     Program Office provided the Task Force with two options
                     regarding audits for the SHP subrecipients, as noted in the
                     finding. The Task Force was responsible for obtaining
                     audits for SHP subrecipients in accordance with OMB
                     Circular A-133. Audits of the SHP subrecipients are to be
                     conducted by an auditor independent of the Task Force’s
                     operations.




98-AT-251-1009            Page 28
                                                                 Finding 3



Recommendations   We recommend that you require the Task Force to:

                  3A.    Implement monitoring reviews that perform
                         knowledgeable oversight of its SHP subrecipients in
                         program services and in financial management.

                  3B.    Establish and implement a tracking system which
                         provides assurance that all Annual Performance
                         Reports will be received from the SHP subrecipients
                         in a timely manner.

                  3C.    Provide SHP fund assistance in obtaining the
                         financial audits from its SHP subrecipients.




                           Page 29                            98-AT-251-1009
Finding 3




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98-AT-251-1009                Page 30
Management Controls
In planning and performing our audit, we considered the management controls of the Task Force in
order to determine our auditing procedures and not to provide assurance on the controls. Management
controls 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
 Relevant management                   relevant to our audit objectives:
 controls

                                           •   Management philosophy and operating style.

                                           •   Eligibility and support of grant activities.

                                           •   Management monitoring methods.

                                           •   Reliability of financial systems and reporting.

                                           •   Accounting for and maintaining control over
                                               program disbursements.

                                           •   Measurement of program results.

                                       A significant weakness exists if management controls do not
                                       provide reasonable assurance that the process for planning,
                                       organizing, directing, and controlling program operations
                                       will meet an organization’s objective. Based on our review,
                                       significant weaknesses existed in the management controls
                                       we tested as discussed in the findings.




                                                Page 31                                 98-AT-251-1009
Management Controls




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98-AT-251-1009                     Page 32
Follow Up On Prior Audits
This was the first Office of Inspector General audit of the Task Force’s grant operations.

The last Independent Auditor audit report was completed by Robert E. Smith, Certified Public
Accountant, for the year ended December 31, 1995. The report disclosed the following
deficiencies in MATFH’s operations that relate to the findings of this report:

       •   Failure to obtain documentation from the subrecipients to support payments made to
           subrecipients.

       •   Failure to update and reconcile spreadsheets, which it used to track grant funds, to the
           general ledger.




                                               Page 33                               98-AT-251-1009
Follow Up On Prior Audits




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98-AT-251-1009                    Page 34
                                                                                                        Appendix A


Schedule Of Unsupported and Ineligible Costs

                                                     Amounts                        Amounts
               Recommendations                      Unsupported2                   Ineligible3

               1A                                       $ 1,243,854
               1B                                                                      $ 6,607
               2E                                               66,427
               2F                                                                            760
               2G                                                                          8,824

               Totals                                  $ 1,310,281                     $ 16,191




2
  Unsupported amounts do not obviously violate law, contract, policy or regulation, but warrant being contested
for various reasons such as lack of satisfactory documentation to support eligibility.
3
    Ineligible amounts obviously violate law, contract, HUD or local agency policies or regulations.

                                                      Page 35                                          98-AT-251-1009
Schedule Of Questioned Costs




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98-AT-251-1009                    Page 36
                                                                                                 Appendix B


Auditee Comments

                        Task Force For The Homeless
                   363 Georgia Avenue, SE, Atlanta, Georgia 30312
                              (404) 230-5000        FAX 589-8251

   July 10, 1998


   Ms. Nancy H. Cooper
   District Inspector General
    for Audit – Southeast/Caribbean
   US Department of HUD
   Richard B. Russell Building
   75 Spring Street, SW, Room 330
   Atlanta, Georgia 30303-3388


   Dear Ms Cooper:

   This is the beginning of our response to your draft findings, dated July 2, 1998.

   We have reviewed the draft and have provided our auditor with a copy. In fact the draft report
   listed many issues that we felt sure we had resolved in the audit itself.

   We want to respond to all of the concerns reported in that draft in this letter, and as thoroughly as
   possible. To that end, we also request a meeting with you and your Auditors as soon as possible.
   We ask that this meeting be held in order to resolve the draft issues before the exit meeting that we
   know we will have to close out this process. In other words, we want to meet immediately
   BEFORE this report is finalized.

   We are happy to cooperate with you in whatever way we can. It was extremely difficult though,
   to have your auditors performing their audit at the same time we had our external auditors
   performing the 1996 and 1997 audits. That resulted in our having to locate your auditors in our
   conference room, which is the meeting room for our many teams and for our staff. However, we
   all cooperated to the best of our ability.

   Please let me know when you can meet with us to talk about revising this draft.

   Sincerely,


   Executive Director

   Enclosure
    copy: Mr. Norman Ross, CPA




                                               Page 37                                        98-AT-251-1009
Auditee Comments

       Finding I

       CRITERIA:

       You misstated our procedures for 1994 IHP and IHP 1995 grants. The procedures you describe
       pertain to our SHP Procedures only. We informed you of that fact before the exit meeting.


       Innovative Homeless Program Was Not Effectively Administered:

       You stated that we did not effectively administer our 1994 and 1995 IHP grants for the following
           reasons:     MATF did not

       (1) adequately document payments to sub recipients:

       We did document the expenditures to subrecipients; however, we requested and received the funds
       in advance and documented the expenditures accordingly. Therefore, the documentation is not
       arranged to correspond to the draws because we had not been required to do that at the time. But
       the documentation corresponds to the total expenditures of grant funds.

       You questioned “five of ten vouchers," and we drew funds down every month. Once again, we
       documented the expenditures, not the draws by amount.

       We request that you delete this finding.

       (1a) The 1994 IHP Payments were not Properly Supported

       We did provide adequate documentation, as we stated. Draws were documented after the fact and
       did not match specific drawdown request amounts but documented the total expenditures. Again,
       we drew the money in advance for requests from sub recipients, not matching reimbursement
       requests which came later, as we received them from subrecipients.

       As for the missing subrecipient documentation and contract files, we have staff documentation of
       our having provided those files to you during the audit visit. We even observed that one of your
       auditors was searching for a file under “AUM" instead of Atlanta Union Mission, and he looked
       for files in the wrong order. Eventually he was shown the files, which has been in the box all
       along.

       We need to know what this finding refers to since WE located the files again for the auditor who
       had failed to look in the files under the correct and complete name.

       (1b) The 1995 W Payments were not properly supported;

       The same thing applies here. Please provide documentation for the $84,558 you say we did not
       support. We were not given that information. Also, the funds used in this grant paid sub
       recipients for staff salaries.

       As for the sub recipients not properly documenting client eligibility, we informed your auditors
       several times that our hotline was the documentation for client eligibility. We were given a list of
       clients to test our hotline database -- we provided intake documentation on all clients submitted by
       name to us by your auditors. We also reminded the auditors that the HUD regulations governing




98-AT-251-1009                                    Page 38
                                                                                           Appendix B


the homeless eligibility/verification documentation was published in October 1995, well after both
IHP grants had been implemented.

Please delete the questioning, therefore, of $167,318 because of what you term "unsupported
subrecipient payments."

You say that 61 % of the 1995 Administrative charges were unsupported. We submitted the admin
budget to the program office in the first half of 1996, and they approved that budget. Unless you
use the time sheets for the fifth person who was charged and approved you cannot say we
overcharged the grant. We had also submitted the documentation for the cost and that
documentation was accepted. Therefore, please provide your working papers to support this
claim.

Site Visits Performed at Subrecipients;

Again you maintain that we had insufficient documentation to prove the number of persons served.
We are unclear as to the grant you refer to -- are you referring to IHP 1995?

If so, you cite yourself that the HUD circular was not issued until October 19, 1995. We began
the program in July of 1995. We informed you that our hotline intake database was used to
document client eligibility. You even asked to check a sample of clients. We provided you with
that information.

You state that our manual requires adequate client documentation, and that manual refers only to
SHP sub recipients.

You say that no monthly progress reports were not available. They were and are available and
were submitted by sub recipients at the time they submitted reimbursement requests.

We request that you delete this paragraph.

(2a) Eligibility of Homeless Clients Was Not Verified:

We informed you that our hotline database and our referral to subrecipient agencies for service
qualified as client verification. That verification was accepted by HUD prior to implementation of
the contract. We even told you that we provided that service to keep clients from having to be
interviewed and documented more than once with the same information.

Please explain what you mean by our not documenting services received by the client -- what other
than the intake form and referral were we to document? The grant was for outreach, intake and
referral -- what other than the intake form?

One of the sub recipients you interviewed was an Outreach subrecipient, whose documentation
was eyeballing people on the streets and using our database and referral information.

Your auditors continue to confuse the three contracts and misinterpret the guidance for SHP as
applying to IHP.

On your page 4 of 5, you make some serious allegations and misrepresent the conversation with
our staff. We have all reviewed this information and are extremely concerned that such inaccurate
editorial comments would be included in a document like this. First, we never even hinted that we
told subrecipeints not to document client eligibility -- we did say that our database and referral
system was accepted by HUD as that documentation. If you had requested, we could have


                                               Page 39                                   98-AT-251-1009
Auditee Comments



       provided you with a "blind” copy of the three screens worth of detailed information we get from
       each client. Our intake database has been reviewed by HUD program officials many times.

       You state that the Executive Director said the HUD documentation requirements applied only to
       SHP and you quote our Procedures Manual -- it is the procedures manual for SHP, not IHP.
       Please let us clarify this issue once and for all.

       (3) Number of Homeless Clients Served Was Not Documented:

       Once again you claim that we did not document or have sub recipients document the number of
       clients served. They did document clients served in their monthly progress reports, submitted
       prior to reimbursement.

       You further iterate that we did not document clients served or verify homelessness of those clients.
       Please document to us what you claim the HUD field office reported. We are not aware that they
       claimed that the problem “presently continues."

       (4) Audits for Subrecipients Were Not Obtained:

       You state that audits were due from 10 of the 1994 and 5 of the 1995 sub recipients. One of your
       auditors requested an audit for Atlanta Union Mission and for the Task Force for the Homeless,
       both of which he received. We are unaware of any other requests. No Task Force staff who
       could answer officially could have said we didn't “know if the sub recipients had obtained the audits."

       (5) Final Close-Out Report for the 1995 IHP Grant Was Not Completed:

       Correct. We still have a balance not drawn down of over $5,000. This is program cost that we are
       sure we will expend for outreach.

       We did NOT say we submitted a close out report. We said we submitted an Annual Report.

       Technically the 90 days after completion of the award should not begin until we have expended the
       funds.

       Please correct this finding accordingly.


       Finding 2

       Accounting Records:

       You make extreme, and damaging observations about the Task Force's accounting system which
       are general and unfounded. We want to respond to each one.




98-AT-251-1009                                    Page 40
                                                                                              Appendix B



Accounting System Was Inadequate:

Expenses Were Inadequately Tracked:

The Task Force did, indeed, establish general ledger accounts to record and track SHP grant costs
by subrecipient line items. In fact, those accounts were reviewed by the OIG staff in a preliminary
review of our accounting system priori to our drawing down any funds for the SHP; the system
was also reviewed and approved by the HUD Program Financial Staff person.

The spreadsheets were set up and maintained as part of our official accounting records and
approved by the HUD program office prior to our drawing down any funds. We used the
spreadsheets as a subsidiary ledger. The General Ledger was used to record the total transaction,
while the spreadsheets were used to record the itemized components of each total transaction.

You also stated that the spreadsheets contained inaccurate information and that therefore the
accounting records did not accurately reflect a true and complete accounting of the subrecipient
grant position. You cite that an expenditure on spreadsheet from a subrecipient was $14,042 and
actual expenditure as $15,052. We want to review your work papers for this finding. If the
amount you cited is your evidence for the finding, we strongly object to your dismissal of our
entire accounting system on that basis.

We strongly object to the finding for the above reasons, and we request that the finding be
modified accordingly.

The Executive Director did indeed state that there had been staff turnover and a new accounting
software system implemented. The implication that she also said this whole accounting experience
was a “learning experience" is inaccurate at best and deliberately misleading at worst.

You also cite inaccuracy of spreadsheets when balanced with general ledger amounts for
administrative costs. We told you repeatedly that according to spreadsheets and some time sheets,
we applied time to the grant which we did not actually charge or get reimbursed for.

Again, you state that we budgeted salary cost of $25,000 for Accounting Assistant and did not
charge the grant. That was a record keeping issue, to record actual cost. We also told you that the
variation of time spent from 100% to 45 % was for budgeting purposes since we do not use an
Indirect Cost Plan but budget by percentage, which works out on an annual basis.

What employee did we pay from this contract who was not included in the HUD budget or on our
spreadsheet?

The final paragraph is of great concern. WHAT Task Force officials could not tell your auditors
which set of records reflected correct financial information?

Since we were told several different ways to request administrative reimbursement, we want to say
again that we drew our administrative funds in a way that was reviewed and approved by the HUD
program office. We have a record of the meeting and the names of those in attendance, should you
require that information.




                                               Page 41                                    98-AT-251-1009
Auditee Comments



       Grant Activity Was Not Properly Disclosed:

       You state that our accounting records contained inaccurate and incomplete information, for
       example:

       * the ending SHP account balances from 1996 were not brought forward as beginning balances in
       the 1997 general ledger;

       It is a matter of record that your office insisted on beginning the audit while we were undergoing
       our 1996 audit and as a result of course we had not carried forward the balances until the audit was
       complete. We told you this in the beginning. You insisted on beginning your audit before we had
       had an opportunity to complete our 1996 audit. How can you cite us for something when you
       insisted on beginning without that information? Also, the SHP balances were being maintained
       and were current on our spreadsheets, which we consider and stated are part of our official
       accounting records.

       In fact, we used the spreadsheets to serve as a check and balance for detail the General Ledger does
       not provide.

       * Yes, we used our administrative account to record reimbursements and costs incurred but not yet
       paid. How could we not? We accumulated unreimbursed costs and still plan to get that
       reimbursement from HUD. We are happy to establish a separate account for costs incurred but not
       yet paid. But why must that be a separate account? We must carry all grant receivables as we have
       been directed by our auditor.

       * We provided you with that very documentation and showed YOU where we noted the
       discrepancy on the spreadsheet. If we incorrectly recorded or applied an admin draw of $2,454 to
       the program account, and we pointed it out to you that we were aware of the error, why would you
       include this in a finding without pointing that out?

       *Please tell us the specifics of your citation in third paragraph on 3 of 5.
       Program Costs Were Not Properly Supported;

       How could you iterate that claim when you cite only 2% of the expenditures as unsupported ? And
       in your explanation you do not specify which sub recipients you refer to. Since we drew down
       amounts documented as reimbursable, we must know what documentation you are considering
       rejecting. We discussed this issue thoroughly, and we provided you with substantial additional
       documentation as well as copies of letters we sent to sub recipients. The grant continues, along
       with our opportunity to require documentation before future disbursements are made.

       You stated that our employee time sheets did not always support the salary percentages charged to
       the program, and we have explained that. As long as the salary that we actually received
       reimbursement for was documented, it could not matter if MORE than that were documented.

       We know that budgeted percentages do not qualify as support for charges; in fact, that is what we
       have been saying to you all this time. The actual time sheets more than support the charges.

       You stated that we overcharged a consultant $7,715 to the SHP contract. As documented in his
       time sheets, he spent 100% of his time on the SHP contract activities.

       We OVER DOCUMENTED time attributed to the contract because we did not charge all of that



98-AT-251-1009                                    Page 42
                                                                                           Appendix B

time to the contract.

We request that you change your citation accordingly.

Subrecipients Were Reimbursed Untimely:

You stated that we did not reimburse sub recipients in a timely manner. We did, however, obtain
HUD approval for a 30-day turn around for reimbursement procedures. Because we are required
to affirm the documentation for reimbursement requests, we frequently receive the funds before we
have obtained additional documentation. The HUD CPD Program Office approved the 30-day turn
around.

We had documented to HUD and to the sub recipients the reason for some of the delays. As you
have observed, there is a need for adequate documentation from the sub recipients. Also, as
evidenced by this draft, the requirements for documentation seem to differ between the OIG and
the Program Office.

Finding 3

Inadequate Monitoring of Subrecpients:

You stated that we could not demonstrate the impact of SHP funds on the homeless population
because of the inadequacy of our monitoring of subrecpients. You made that claim based on three
opinions: (1) that we did not perform monitoring visits in accordance with the terms of the
contract, (2) that we did not monitor the submission of APRS; and (3) that we did not require the
sub recipients to submit progress reports, documentation of client eligibility or obtain financial
audits.

We object to those opinions as follows:

(1) We included the monitoring information in the manual from the IHP grants, both years
programs which required substantially more intense relationships with subreicipents. You are
confusing the manual's references to the programs. We also made visits to sub recipients which
were not recorded as formal monitoring visits but were informal technical assistance and
informational visits.

Subrecipients under the SHP program were not required to submit quarterly progress reports.

In our subrecipient contracts we stated that there would be two monitoring visits, not four.

(2) We went so far as to develop, at our own expense, a computerized software program which,
when used, would accumulate intake information into a complete and ongoing APR - that
software was offered to HUD and we requested that it be required of subrecpients because we
could monitor daily the intake and accumulated client database. We were told by HUD that use of
the database would be voluntary. The software was innovative and noteworthy to the extent that
Federal HUD officials reviewed it and HUD recipient agencies in other states have requested it.

It is important to state here that the HUD program office intervened so frequently in our efforts to
obtain compliance from our sub recipients that our role as administrator for the contract was
seriously hampered. In some cases, subs were allowed to submit their APR forms directly to the
HUD Field Office, completely bypassing our HUD administrative staff.

Our HUD Program Director did, indeed, review documentation to determine and monitor clients
served at subrecipient agencies, but that documentation was never required to be kept at our site.


                                             Page 43                                     98-AT-251-1009
Auditee Comments

       She did not say that she didn't know she needed to review subs' file documentation but that she
       didn't know she needed to keep physical records in her office to PROVE she had reviewed the
       documentation.

       We take strong exception to the general tone of the review as well as the extreme judgments and
       dismissal of

       Off-Site Monitoring procedures Were Not Followed;

       You state that we did not follow our own off-site monitoring procedures because we did not
       require quarterly progress reports. ONCE AGAIN, you have confused the SHP grant with the
       IHP grants. We did not REQUIRE quarterly progress reports. We have already described the
       computerized APR system which allowed for DAILY intake and that accumulated data as
       it went towards the annual date.

       You are correct in saying that the APRs were in some cases submitted late -- we know that. In
       some cases, we needed support from the HUD Program Staff to encourage those reports. We
       have not gotten that support There is evidence that the HUD Program Staff followed up with sub
       recipients about these reports. Would you like to see it?

       We realize that there is a problem with some of the sub recipients in timely submissions of annual
       reports. We are addressing those problems, but they do not mean that we are not following our
       own off-site monitoring procedures. We strongly request that you rework this finding so that it
       accurately expresses the reality.

       The final misquote of the Task Force Executive Director is absolutely unacceptable. The Executive
       Director did not say anything close to the editorial quote: “MATFH's Executive Director stated that
       she decided not to require the subrecipients to submit quarterly progress reports. . . . " because
       they were never required under this program in the first place. The reference was to the important
       production of the computerized APR that the Task Force staff completed at their own expense and
       which could have solved this problem if the HUD program staff had allowed us to require it of the
       subrecipients.

       SITE VISITS PERFORMED AT SUBRECIPIENTS

       The Task Force staff did, indeed, maintain documentation to demonstrate the progress of each
       subrecipient. The nature of that documentation is the question. We were told by the Program staff
       forcefully and frequently that the documentation should be kept at subrecipient sites. There was no
       consistency between what the HUD Program Office required and what the OIG auditors seemed to
       require. We should not be audited on requirements that we were not provided with at the
       beginning of the contract.

       FINANCIAL AUDITS OF SUBRECIPIENTS WERE NOT OBTAINED

       This finding is unacceptable in its entirety. We cannot accept an evaluation of our failure to obtain
       audits when we were actually MADE to relent on that requirement by the HUD Program Staff. In
       one very intense example, we stated that we would not sign a contract with a subrecipient who
       REFUSED in a meeting with the HUD Program Staff to submit an audit to us. We were told by
       the HUD Program Staff that we would be in danger of losing the contract if we continued to hold
       out. We even stated that by relenting on this requirement with ONE subrecipient, we would not be
       able to hold the line with others. We were told we couldn't require the audits if subs didn't want to
       comply-

       We further were told we had to hire a CPA for our fiscal office. We understood that we were to be


98-AT-251-1009                                   Page 44
                                                                                               Appendix B



able to audit subrecipients and to provide technical assistance in fiscal matter. When the time came
for us to perform these visits, we were then told by the Program Office that we had to PAY the
subs for their own audits and couldn't audit them ourselves. We had no funds to pay them for
their audits because the HUD Program Office had required that we hire our own CPA or Auditor.

You state in your draft a version of this reality that is absolutely prejudicial against the Task Force
and its staff. We urgently request that you change the language and the tone of the statement and
the finding itself.

ALSO, it is urgent for us to note that the $259,152 we drew down for our administrative costs was
only HALF of the amount budgeted for two years and we had operated nearly THREE years of
administration based on 5% of the total grant award. (If you divide that by three, our
reimbursement for administering this grant was only $86,384 a year, while the actual approved
budgeted amount was over $200,000 a year.) That budgeted amount was planned for, approved,
and the expenses were incurred. However, HUD has not reimbursed our costs, based upon the
agreed budgeted amount.




                                                 Page 45                                     98-AT-251-1009
Auditee Comments




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98-AT-251-1009                  Page 46
                                                                        Appendix C

Distribution
Secretary's Representative, 4AS
Director of Community Planning and Development, 4AD (2)
Audit Liaison Officer, 3AFI
Administrative Service Center, 4AA
Acquisitions Librarian, Library, AS (Room 8141)
Director, Office of Budget, FO (Room 3270)
Associate General Counsel, Office of Assisted Housing and Community Development, CD
(Room 8162)
Director, Office of Economic Development, DEE (Room 7136)
Assistant Secretary for Community Planning and Development, D
Deputy Assistant Secretary for Grant Programs, DG (Room 7204)
Special Advisor/Comptroller, Community Planning and Development, DOT (Room 7220)
Counsel to the IG, GC
Public Affairs Officer, G
HUD OIG Webmaster-Electronic format via Electronic mail-
    Morris_F._Grissom@Hud.Gov
Director, HUD Enforcement Center, 1240 Maryland Avenue, Suite 200, Washington, DC 20024
Chief Financial Officer, F (Room 10164)
Deputy Chief Financial Officer for Finances, FF (Room 10166)
Director, Housing and Community Development Issue Area, U.S. GAO, 441 G Street N.W.,
  Room 2474, Washington DC 20548
Assistant to the Deputy Secretary for Field Management, SDF (Room 7106)
Assistant to the Secretary for Labor Relations , SL (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
Robert S. Cramer, Jr., Chairman, Board of Directors, Metro Atlanta Task Force
   for the Homeless
Anita Beaty, Executive Director, Metro Atlanta Task Force for the Homeless




                                     Page 47                           98-AT-251-1009