oversight

Columbus HA, Columbus, OH

Published by the Department of Housing and Urban Development, Office of Inspector General on 1998-01-23.

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

                            U. S. Department of Housing and Urban Development
                            Office of Inspector General for Audit, Midwest
                            77 West Jackson Boulevard, Room 2646
                            Chicago, Illinois 60604-3507

                            Phone (312) 353-7832      Fax (312) 353-8866
                            Internet http://www.hud.gov/oig/oigindex.html




                                                  AUDIT RELATED MEMORANDUM
                                                            98-CH-204-1807

January 23, 1998

MEMORANDUM FOR:    David Kellner, Director of Public Housing, Ohio
                     State Office


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

SUBJECT:   Columbus Metropolitan Housing Authority
           Supplemental Police Services
           Columbus, Ohio


We completed a review of the Columbus Metropolitan Housing
Authority's supplemental police services. The review resulted
from issues raised in a City of Columbus, Ohio Mayoral
Investigative Report and congressional inquiries regarding
concerns raised by a constituent as a result of the Mayoral
Investigative Report. The objectives of our review were to
determine whether any of the constituent's concerns were valid.

The specific issues raised by the Mayoral investigation were that
the Housing Authority: (1) may not have had a contract for the
supplemental police services; and (2) may have paid the current
Coordinator of the Authority's supplemental police services, a
Sergeant for the City of Columbus' Division of Police, for
services he did not perform or performed while he was on duty for
the City of Columbus.

The Authority manages 28 developments consisting of over 4,000
units. The Housing Authority spent over $2.5 million on
supplemental police services between January 1992 and September
1997.

The Authority was organized under the laws of the State of Ohio.
A five-member Board of Commissioners governs the Authority. The
Executive Director is responsible for the Authority's day-to-day
operations. The Authority's Executive Director is Dennis Guest.
The Chairman of the Board is Hamilton Teaford. The Authority's
official records are at 960 East Fifth Avenue, Columbus, Ohio.
To achieve our objectives, we reviewed the Housing Authority's:
general ledgers between January 1992 and June 1997; payment
registers between January 1992 and September 1997; supplemental
police officers' time sheets, written work assignment records,
and invoices prepared between January 1992 and September 1997;
IRS Forms 1099 prepared for the supplemental police officers
between 1992 and 1996; the supplemental police services contract
which expired on December 31, 1994; the Cooperation Agreement
with the City of Columbus; the Comprehensive Grant Program's
Annual Statement/Performance and Evaluation Reports for the
periods ending June 30, 1995 through June 30, 1997; the
Authority's audited financial statements for fiscal year 1996;
and Board meeting minutes for 1992.

We also reviewed HUD's files for the Housing Authority, the City
of Columbus's Mayoral Investigative team's files, and the City of
Columbus' Division of Police payroll records. We interviewed the
Housing Authority's staff, HUD's staff, City of Columbus Police
Officers, City of Columbus' Department of Public Safety staff,
and supplemental police officers.

We found no evidence that the Housing Authority paid the current
Coordinator of the supplemental police services for services that
he did not perform or performed while he was on-duty for the City
of Columbus' Division of Police between January 1995 and
September 1997. Since the Housing Authority's records were
missing for 1994, we were unable to determine whether the current
Coordinator was paid for services that he did not perform or
performed while he was on-duty for the City for the three months
he was the Coordinator in 1994. In addition, because the
Columbus Metropolitan Housing Authority did not maintain adequate
documentation, we were unable to determine whether the former
Coordinator was paid for services that he did not perform or
performed while he was on-duty for the City for the time he was
Coordinator between March 1992 and October 1994. As shown in the
two findings which follow, we determined that the Housing
Authority did not always follow its policies and procedures and
HUD's requirements. Specifically, the Housing Authority did not:
(1) adequately maintain the records for the supplemental police
services; and (2) follow its and HUD's contracting requirements
for police services.

We presented our draft findings to the Authority's Executive
Director during the audit. We held an exit conference with the
Authority's Board Chairman, Executive Director, and Director of
Finance and Administrative Services on December 15, 1997. The
Authority provided written comments to our findings. We
considered the comments in preparing our memorandum. The
complete text of the comments are in Appendix A.

Within 60 days, please give us, for each recommendation made in
the memorandum, a status report on: (1) the corrective action
taken; (2) the proposed corrective action and the date to be


98-CH-204-1807                 Page 2
                                                          Finding 1



completed; or (3) why action is considered unnecessary. Also,
please furnish us copies of any correspondence or directives
issued because of the audit.

If your staff has any questions, please contact me at
(312)353-7832.




                               Page 3                   98-CH-204-1807
Finding 1




Records For Supplemental Police Services Were
         Not Adequately Maintained
The Columbus Metropolitan Housing Authority did not ensure that time sheets or written work
assignment records were maintained to support $43,965 paid to the former Coordinator of the
supplemental police services. The Housing Authority also failed to adequately maintain control over
its records to support the supplemental police services provided by other officers in 1994. The
Housing Authority relied on invoices detailing the total hours worked by the Coordinator, not time
sheets or written work assignment records. The Executive Director said he was not aware that the
former Coordinator was not maintaining time sheets or work assignment records. He said the
supplemental police service records for 1994 were either lost or misplaced. As a result, HUD and
the Housing Authority lack assurance that the payments for supplemental police services were
reasonable and necessary.



                                      Section 309 of the Annual Contributions Contract states in
 HUD Requirements
                                      part that the Local Authority shall maintain complete and
                                      accurate books of account and records.

                                      Starting in March 1992, HUD allowed housing authorities to
                                      use Comprehensive Grant Program funds for additional police
                                      services. HUD Handbook 7485.3, the Comprehensive Grant
                                      Program, page 4-12, states in part that Comprehensive Grant
                                      Program funds may be used to pay for the cost of additional
                                      on-duty police services. The services shall be verifiable
                                      through time sheets and written work assignments.

                                      24 CFR Part 85.36(i)(11) requires that grantees or
                                      subgrantees must retain all required records for three years,
                                      after final payments and until all other pending matters are
                                      closed.

                                      The Columbus Metropolitan Housing Authority failed to
 Former Coordinator's time
                                      ensure that time sheets or written work assignments were
 sheets were not maintained
                                      maintained to support the former Coordinator's services. The
                                      Housing Authority executed a Memorandum of Understanding
                                      with the City of Columbus, Ohio in 1992 for supplemental
                                      police services. The former Coordinator, an officer for the
                                      City of Columbus' Division of Police, supervised the Housing
                                      Authority's supplemental police officers.

                                      The Housing Authority paid the former Coordinator $44,701

98-CH-204-1807                                 Page 4
                                                                                 Finding 1



                           between March 1992 and October 1994. We found one time
                           sheet that supported $736 of the former Coordinator's services
                           in 1994, after the current Coordinator took over. However,
                           $43,965 in payments were not supported by time sheets or
                           written work assignment records. The former Coordinator
                           said he did not maintain time sheets or written work
                           assignment records. The Housing Authority relied on invoices
                           detailing the total hours worked by the Coordinator during
                           two week time periods. The invoices did not detail the daily
                           hours worked or the nature of the services provided by the
                           former Coordinator. We were unable to compare the scope
                           of the former Coordinator's services to the current
                           Coordinator. When the current Coordinator started, the
                           Housing Authority required that he be on call during the same
                           hours as the supplemental police officers. The former
                           Coordinator was not required to maintain an on call status.

                           During the audit, we reviewed documentation such as
                           biweekly activity reports and payroll invoices that supported
                           the supplemental police services performed by the former
                           Coordinator for which he was paid.               However, the
                           documentation did not support the reasonableness of the
                           former Coordinator's services or that his services were
                           necessary. The biweekly activity reports summarized the
                           supplemental police officers' services such as resident contacts
                           and arrests. The invoices only provided the total hours
                           worked by the officers during each two week time period, not
                           the hours or the location worked per day. The Executive
                           Director said he was not aware that the former Coordinator
                           did not maintain time sheets or written work assignment
                           records. As a result, HUD and the Housing Authority lack
                           assurance that the cost of the former Coordinator's services
                           were reasonable and necessary. The current Coordinator has
                           maintained time sheets and written work assignment records
                           to support his services.

                           The Housing Authority could not provide adequate
Documentation to support
                           documentation to fully support the supplemental police
services from 1994 were
                           services provided by other officers in 1994. As previously
missing
                           stated, HUD allows housing authorities to use Comprehensive
                           Grant Program funds for additional police services; however,
                           the services must be verifiable through time sheets and written
                           work assignment records. Excluding the former Coordinator's
                           services for 1994 discussed above, the Housing Authority


                                    Page 5                                    98-CH-204-1807
Finding 1



                    spent $482,735 in Comprehensive Grant funds for
                    supplemental police services. The Housing Authority
                    provided time sheets and written work assignment records to
                    support $122,236 of the supplemental police services.
                    However, the Housing Authority was unable to provide time
                    sheets and written work assignment records for the remaining
                    $360,499.

                    Although the Housing Authority lacked time sheets and
                    written work assignment records for the $360,499, we found
                    evidence that services were performed for the payments made.
                    The Housing Authority had invoices that supported the total
                    hours charged for during each two week pay period for the
                    supplemental police officers in 1994. Further, the cost of the
                    1994 supplemental police services appeared reasonable in
                    relation to the cost of the services in 1993 and 1995 that were
                    supported by time sheets and written work assignment
                    records. There were also activity reports that showed over
                    7,600 resident contacts and 112 arrests made by the
                    supplemental police officers between December 20, 1993 and
                    December 31, 1994. The activity reports and invoices for the
                    other supplemental police officers supported the services in
                    1994 because the reports provided a summary of the officers
                    patrols by pay period. However, there were no activity
                    reports to support the former Coordinator's services as
                    discussed above.          The Executive Director said the
                    supplemental police service records for 1994 were either lost
                    or misplaced. As a result, HUD lacks assurance that the
                    services were necessary.



Auditee Comments    [The] Columbus Metropolitan Housing Authority will work
                    with the Director of Public Housing, Ohio State Office, to
                    determine what documentation may be appropriate for
                    supporting the [former] Coordinator's services between March
                    1992 and October 1994. [The] Housing Authority will [also]
                    ensure that all appropriate records are maintained [for] three
                    years past the date of our annual [Independent Public
                    Accountant's] audits.


OIG Evaluation of   The action proposed by the Housing Authority regarding
Auditee Comments    working with the Director of Public Housing, Ohio State
                    Office, should resolve the issue of the former Coordinator's


98-CH-204-1807               Page 6
                                                                                        Finding 1



   unsupported costs, if adequate documentation can be provided to support the reasonableness and
   the necessity of his services. If the Housing Authority cannot provide the required
   documentation, then the Authority should reimburse HUD $43,965 from non-Federal funds, the
   amount paid to the former Coordinator that was not supported.

                                    While the Housing Authority's comments addressed the
                                    procedures it plans to use regarding the retention of its
                                    records, the Housing Authority did not address the controls it
                                    plans to implement over its records. The Housing Authority
                                    should establish controls over its records which includes an
                                    inventory of the records and their location.

                                    The Housing Authority did not address the recommendation
                                    regarding establishing procedures and controls to assure the
                                    practice of supplemental police officers maintaining time
                                    sheets and written work assignments continues. Even though
                                    the Housing Authority currently maintains time sheets and
                                    written work assignment records, procedures and controls
                                    must be established to ensure that this process continues.



Recommendations                     We recommend that the Director of Public Housing, Ohio
                                    State Office, assures the Columbus Metropolitan Housing
                                    Authority:

                                    1A.        Provides adequate documentation to support the
                                               $43,965 in Comprehensive Grant Program funds
                                               paid to the former Coordinator between March
                                               1992 and November 1994.           If adequate
                                               documentation cannot be provided to support the
                                               reasonableness and the necessity of the former
                                               Coordinator's services, the Housing Authority
                                               should reimburse HUD $43,965 from non-Federal
                                               funds.




                                             Page 7                                   98-CH-204-1807
Finding 1



                 1B.     Establishes procedures and controls to assure that
                         the practice of supplemental police officers
                         maintaining time sheets and written work
                         assignments continues.

                 1C.     Establishes procedures and controls over its
                         records which includes an inventory of the records
                         and their location.




98-CH-204-1807         Page 8
                                                                                           Finding 2




  Contracting Requirements For Police Services
               Were Not Followed
The Columbus Metropolitan Housing Authority did not follow its Procurement Policy and Procedures
Manual and HUD's requirements for the procurement of supplemental police services. Specifically,
the Housing Authority: (1) did not define baseline services provided by the local police department;
(2) failed to execute a written contract after the previous supplemental police services contract had
expired; and (3) did not document its Board of Commissioners' approval authorizing the execution
of the supplemental police services contract. These issues existed because the Housing Authority
lacked adequate controls over its contracting system. As a result, HUD and the Housing Authority
lacks assurance that police services were reasonable, necessary, and authorized.



                                      HUD Guidebook 7485.3 G, the Comprehensive Grant
 HUD Requirements
                                      Program, Appendix 2-1, page 5, states that housing authorities
                                      should define the current local police department's level of
                                      baseline services to the housing authority and its residents.
                                      Baseline services are ordinary and routine services provided to
                                      residents as a part of the overall city and county-wide
                                      deployment of police services. Housing authorities must
                                      define the baseline services to include the number of officers
                                      and equipment and the actual percent of their time assigned to
                                      the housing authority's developments. Housing authorities
                                      should also demonstrate to what extent an activity will
                                      represent an increase over and above the baseline services.

                                      Appendix 2-1 of the Guidebook, page 6, states in part that to
                                      reimburse the local law enforcement agency for additional
                                      security and protective services, the housing authority shall
                                      execute a long-term law enforcement service agreement with
                                      the primary law enforcement provider. The law enforcement
                                      provider may be the local police, sheriff and/or the State.
                                      Expenditures shall not be incurred by the housing authority
                                      and/or funds released by the HUD Field Office until the
                                      housing authority and the local law enforcement agency
                                      execute a contract for the additional law enforcement services.

                                     The Housing Authority's Procurement Policy and Procedures
 Housing Authority's
                                     Manual effective July 1, 1990 required that the
 Requirements
                             Board of Commissioners approve all contracts over $15,000, before
award. The Housing Authority revised its Policy on April 26, 1996. The revised Policy required that
                             the Board approve the award of contracts exceeding $25,000.
 Cooperation Agreement's
 Requirements                        The Cooperation Agreement dated June 18, 1969 between the


                                                Page 9                                   98-CH-204-1807
Finding 2



     Housing Authority and the City of Columbus, Ohio states in part that the City, without cost or
     charge to the Authority, shall furnish public services and facilities of the same character and to
     the same extent as are furnished to other dwellings and inhabitants of the City.

                                       The Housing Authority did not document its Board of
 Board's approval was not
                                       Commissioners' approval awarding the 1992 supplemental
 documented
                                       police services contract. Good internal control requires that
                                       the Authority document the Board's approval of contract
                                       awards. The Housing Authority executed a Memorandum of
                                       Understanding for supplemental police services with the City
                                       of Columbus, Ohio. The Memorandum of Understanding was
                                       effective for the period May 1992 to December 31, 1994 and
                                       could not exceed $1.4 million. The Director of Finance and
                                       Administrative Services said the Board discussed the award of
                                       the 1992 contract while in executive session and later
                                       approved it in open session, but the approval was not
                                       documented.

                                       The Housing Authority did not execute a written contract
 The contract expired but
                                       after the 1992 contract had expired in 1994. As previously
 services continued
                                       stated, the Housing Authority executed a Memorandum of
                                       Understanding with the City of Columbus in 1992. Written
                                       contracts are necessary to define the scope of services and
                                       assist in monitoring contractors performance.           The
                                       Memorandum expired on December 31, 1994 and no
                                       additional contracts were executed. The Housing Authority
                                       continued to pay for the supplemental police services
                                       according to the expired Memorandum of Understanding.
                                       The Memorandum of Understanding required the Housing
                                       Authority to pay according to the contract between the City
                                       of Columbus and the Fraternal Order of Police. The Housing
                                       Authority's management was not aware that the Memorandum
                                       of Understanding had expired until we brought it to their
                                       attention.




98-CH-204-1807                                  Page 10
                                                                                   Finding 2



                              The Columbus Metropolitan Housing Authority failed to
 Baseline services were not
                              define the baseline services provided by the local police
 defined
                              department. Baseline services are defined as ordinary and
                              routine services provided to residents as part of the overall
                              city and county-wide deployment of police services, such as
                              911 emergency calls. The Housing Authority should have
                              defined baseline services to ensure the desired services were
                              above what the local government is required to provide at no
                              cost to the Authority. The Memorandum of Understanding
                              with the City of Columbus, Ohio executed in 1992 did not
                              define the baseline services. The Executive Director believed
                              that the Housing Authority was receiving services over and
                              above baseline services.

                              The Housing Authority inappropriately paid for baseline police
 Authority paid less than
                              services. Baseline police services are services that the local
 $700 for baseline police
                              government must provide to the Housing Authority and its
 services
                              residents at no cost, such as 911 emergency calls. We
                              determined that the Housing Authority was paying for baseline
                              services. Between January 1, 1995 and June 30, 1997, the
                              Housing Authority spent less than $700 in Comprehensive
                              Grant Program funds for the supplemental police officers to
                              respond to 911 emergency calls. The special duty police
                              officers said the City of Columbus' Police policies required
                              them to respond to emergency calls. We found no evidence
                              that the Housing Authority was paying for baseline services
                              from 1992 through 1994.

                              As a result of the issues discussed above, HUD and the
                              Housing Authority lack assurance that the supplemental police
                              services were reasonable, necessary, and authorized.



Auditee Comments              On November 21, 1997[,] the Housing Authority['s] Board of
                              Commissioners passed [a] resolution pertaining to off-duty
                              police services. [The] Housing Authority has conveyed to the
                              Mayor of Columbus [an] Intergovernmental Agreement
                              concerning the utilization of off-duty police officers for non-
                              basic services. [The] Authority is awaiting the return of the
                              signed Agreement.

                              [The] Housing Authority has entered the expiration date [of
                              the Intergovernmental Agreement] into its tracking system for
                              multi-year contracts. This will prevent a reoccurrence of
                              operating under an expired Agreement.



                                       Page 11                                  98-CH-204-1807
Finding 2



OIG Evaluation of   The Housing Authority's Board of Commissioners authorized
Auditee Comments    the execution of the Intergovernmental Agreement with the
                    City of Columbus. However, the Housing Authority did not
                    indicate what procedures and controls it plans to implement to
                    assure that it documents the approval from its Board of
                    Commissioners for future contracts. The Housing Authority
                    should show that it follows its Procurement Policy and
                    Procedures Manual by documenting the approval from its
                    Board of Commissioners for the award of contracts.

                    The actions taken by the Housing Authority, if fully
                    implemented, should resolve the issue of executing a written
                    agreement for the supplemental police services. However, the
                    Housing Authority did not address the recommendation of
                    defining baseline services. The Housing Authority should
                    establish procedures and controls to follow HUD's
                    requirements regarding defining baseline services from the
                    local police department. Once baseline services are defined,
                    the Housing Authority should establish procedures and
                    controls to ensure the Authority does not pay for baseline
                    police services in the future.



Recommendations     We recommend that the Director of Public Housing, Ohio
                    State Office, assures that the Columbus Metropolitan Housing
                    Authority:

                    2A.        Establishes procedures and controls to follow
                               HUD's requirements, including but not limited to:
                               (1) defining baseline services from the local police
                               department; and (2) executing a written agreement
                               for the supplemental police services. Once
                               baseline services are defined, establish procedures
                               and controls to ensure the Housing Authority does
                               not pay for baseline police services.

                    2B.        Establishes procedures and controls to follow its
                               Procurement Policy and Procedures Manual,
                               including but not limited to documenting the
                               approval from its Board of Commissioners for the
                               award of contracts.




98-CH-204-1807              Page 12
                                                                                      Appendix A

Auditee Comments

Contracting Requirements for Police Services Were Not Followed:

Response:

1. On November 21, 1997 the CMHA Board of Commissioners passed the attached resolution
pertaining to off-duty police services. Additionally, CMHA has conveyed to the Mayor of
Columbus the Intergovernmental Agreement concerning the utilization of off-duty police officers
for non-basic services. CMHA is awaiting the return of the signed agreement.

2. CMHA has entered the expiration date into it's tracking system for multi-year contracts for the
above mentioned Intergovernmental Agreement. This will prevent a reoccurrence of operating
under an expired agreement.


Records for Supplemental Police Services Were Not Adequately Monitored

Response:

1. CMHA will work with the Director of Public Housing, Ohio State Office, to determine what
documentation may be appropriate for supporting the coordinator's services between March 1992
and October 1994.

2. CMHA will ensure that all appropriate records are maintained three years past the date of our
annual IPA audits.




                                              Page 13                                  98-CH-204-1807
Appendix A



RESOLUTION NO. 5687

AUTHORIZING THE EXECUTIVE DIRECTOR TO ENTER INTO AN
INTERGOVERNMENTAL AGREEMENT WITH THE CITY OF COLUMBUS TO PROVIDE
SUPPLEMENTAL POLICE SERVICES IN ALL CMHA HOUSING COMMUNITIES

     WHEREAS the Executive Director has determined that additional police services are
necessary in CMHA housing communities and that these services can only be provided by the
Police Department of the City of Columbus; and

    WHEREAS these additional services are a form of community policing which require direct
and personal interaction between police officers and CMHA residents in an effort to reduce crime
and the fear of crime; and

    WHEREAS this type of police patrolling would be performed by off-duty police officers who
would supplement the normal or "base-line" police patrols that are typically used throughout the
City; and

    WHEREAS CMHA must enter into an Intergovernmental Agreement with the City of
Columbus to obtain the additional police services; now therefore

    BE IT RESOLVED by the CMHA Board of Commissioners that the Executive Director is
hereby authorized to enter into said Intergovernmental Agreement with the City of Columbus for a
biannual amount not to exceed $510,000.

                           COLUMBUS METROPOLITAN HOUSING AUTHORITY


                           Chairman


ATTEST:


Secretary


ATTACHMENT


ADOPTED:

November 21, 1997



98-CH-204-1807                               Page 14
                                                                                                                           Appendix A



                                                INTERGOVERNMENTAL AGREEMENT

     This agreement, made this             of         1997 by and between The City of Columbus and the Columbus Metropolitan
Housing Authority hereby agree that:

       In some public housing projects there is a need for law enforcement services that emphasizes a partnership between police and the
residents and the management of the housing authority to prevent crime by addressing the conditions and problems that lead to criminal
activity. This form of community policing requires direct and personal interaction by police officers with the residents in an effort to
reduce crime and the fear of crime.

      In recognition of the above stated approach to crime control in the housing projects, the Columbus Metropolitan Housing
Authority requests the assistance of the City of Columbus Police Department to make available the following police services in all
housing projects from November 21, 1997 through November 20, 1999.

      1. assign off-duty police officers to conduct walking patrols in all family and senior citizen housing projects so as to
supplement normal police patrolling.

      2. by mutual agreement between the Columbus Metropolitan Housing Authority and the Columbus Police
Department, the Police Department shall name and assign a ranking police sergeant to supervise, coordinate,                     monitor and
report on the performance of the officers and effectiveness of the program.

      3.   attend and participate in community meetings with the residents and management of these projects.

      4. provide daily and summary reports to the CMHA Chief of Safety and Crime Prevention regarding the police
services and activities and further make appropriate recommendations to enhance the program if needed.

      5.   maintain payroll records for submission to CMHA.

      Within 60 days from the inception of this Intergovernmental Agreement, the assigned Police Supervisor will meet with the
CMHA Chief of Safety and Crime Prevention who will assist him in developing an operations plan defining the specific duties and
responsibilities of the assigned police officers and the police supervisor, criteria for selecting which housing projects should be patrolled
and to what degree, types of reports to be rendered and additional services that may be needed in the future to deal with specific crime
prevention programs.

      The Columbus Metropolitan Housing Authority shall use appropriate funds from the U.S. Department of Housing and Urban
Development for these police services in an annual amount not to exceed $255,000. Payment will be made to the officers in accordance
with the city established rate-of-pay for off-duty police.

      This agreement may be terminated by either party upon 30 days written notification to the other party.

      In witness thereof, The City of Columbus and the Columbus Metropolitan Housing Authority have executed this agreement on
the date written above.

FOR THE CITY OF COLUMBUS                                              FOR COLUMBUS METROPOLITAN
                                        HOUSING AUTHORITY


Gregory S. Lashutka                                               Dennis S. Guest
MAYOR                                                           EXECUTIVE DIRECTOR


Witness                                                        Witness


Witness                                                        Witness




                                                                  Page 15                                                  98-CH-204-1807
                                                                                          Appendix B

Schedule of Unsupported Costs

                    Recommendation         Unsupported
                       Number               Costs

                          1A              $43,965


Unsupported costs are costs charged to a HUD-financed or insured program or activity and
eligibility cannot be determined at the time of the audit. The costs are not supported by adequate
documentation or there is a need for a legal or administrative determination on the eligibility of the
costs. Unsupported costs require a future decision by HUD program officials. This decision, in
addition to obtaining supporting documentation, might involve a legal interpretation or clarification
of departmental policies and procedures.




98-CH-204-1807                                 Page 16
                                                                                Appendix C

Distribution
Secretary's Representative, Midwest
State Coordinator, Ohio State Office (2)
Director of Public Housing, Ohio State Office (2)
Director of Field Accounting, Midwest
Deputy Secretary, SD
Assistant Secretary for Congressional and Intergovernmental Relations, J (Room 10120)
Deputy Assistant Secretary for Public Affairs, W (Room 10220)
Chief of Staff, S (Room 10000)
Counselor to the Secretary, S (Room 10234)
Senior Advisor to the Secretary for Communications and Policy, S (Room 10222)
Field Comptroller, Midwest
Assistant General Counsel, Midwest
Assistant to the Deputy Secretary for Field Management, SDF (Room 7106)
Comptroller/Audit Liaison Officer, Public and Indian Housing, PF (Room 5156) (3)
Director of Administrative Service Center, New York State Office
Assistant Secretary for Public and Indian Housing, P (Room 4100)
Assistant to the Secretary for Labor Relations, (Acting), SL (Room 7118)
Acquisitions Librarian, Library, AS (Room 8141)
Chief Financial Officer, F (Room 10164) (2)
Deputy Chief Financial Officer for Finance, FF (Room 10164) (2)
General Counsel, C (Room 10214)
Associate General Counsel, Office of Assisted Housing and Community Development, CD
(Room 8162)
Director, Housing and Community Development Issue Area, U.S. GAO, 441 G Street N.W.,
Room 2474, Washington DC 20548, Attn: Judy England-Joseph
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
Executive Director, Columbus Metropolitan Housing Authority
Chairman of the Board of Commissioners, Columbus Metropolitan Housing Authority




                                          Page 17                              98-CH-204-1807