oversight

HA of the City of Crystal City, TX

Published by the Department of Housing and Urban Development, Office of Inspector General on 1998-01-29.

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

January 29, 1998                                                             98-FW-206-1807


MEMORANDUM FOR:                Luz Solis Day, Director, Public Housing Division, 6JPH


FROM: D. Michael Beard, District Inspector General for Audit, 6AGA

SUBJECT:       Housing Authority of the City of Crystal City, Texas
               Fiscal Condition, Procurement, Section 8 Program Eligibility, and
               Administrative Costs


        At your request, we conducted a review of the Housing Authority of the City of Crystal
City , Texas, (Authority). Because of the deterioration in the Authority’s financial condition,
resulting from payment of a lawsuit, and poor contracting practices, we provided you with our
preliminary findings and recommendations on November 14, 1996. This is a follow-up and final
report on the results of the review.

         Based on the concerns expressed by your staff, our review objectives primarily focused
on whether the Authority: (1) has the financial resources to satisfy pending litigation with
current and former employees; (2) procured goods and services in a manner providing free and
open competition free of any conflicts of interest; (3) improperly paid Section 8 rental
assistance to owners for vacant units, or to local officials having a conflict of interest, or to
landlords that were selling the property to the recipient; (4) properly expended funds questioned
by its independent public accountant’s 1994 audit report.

         The preliminary report noted the primary problem facing the Authority is its precarious
financial position resulting from the Authority’s entering into an agreed judgment and payment
of $115,000 to its Executive Director. In addition, the Authority was involved in continuing
litigation with several former employees alleging wrongful termination. The Authority’s
financial situation has not improved. Subsequently, the Authority settled two of the lawsuits
but has a potential liability in excess of $100,000 on the third. Therefore, we are continuing to
recommend close monitoring of the financial condition and litigation status, which may require
your exercise of HUD’s rights under the depository agreements with the Authority’s banks.

        The preliminary report also noted the Authority did not follow HUD and Federal
procurement requirements. The Authority’s procurement practices did not ensure the Authority
was obtaining goods and services at the most reasonable price through open competition and
use of cost and price analyses. Further, the Authority did not have or did not use appropriate
written contracts or, when necessary, obtain HUD approval of the contracts. In accordance
with our preliminary recommendations, you placed the Authority on a preaward review for all
contracts in excess of $500. This final report is questioning $102,208 related to the
procurement transactions conducted prior to the HUD preaward requirement. Although we
determined the Authority did not violate HUD’s former Annual Contributions Contract
conflict-of-interest provisions in awarding two major construction contracts, any such future
contracts will violate the current Annual Contributions Contract’s conflict-of-interest
provisions. We are continuing our recommendation to conduct preaward reviews because of
the Authority’s precarious financial position.
        Our review did not disclose any violation of HUD’s Section 8 Program requirements in
the Authority’s payment of assistance for eligible families and units. The payment of Section 8
assistance to former City officials did not violate HUD’s Annual Contribution Contract conflict-
of-interest provisions. Further, our review did not disclose any improper payment of Section 8
funds for vacant units.

        The Authority’s independent public accountant’s report for the Authority’s 1994 fiscal
year questioned over $20,000 of disbursements. We reviewed these disbursements and
determined that $3,141 represents ineligible costs and that the Authority cannot support the
propriety of another $3,394. Both our review and subsequent independent accountant audits
for fiscal years 1995 and 1996 did not identify any subsequent violations or failure to
adequately document the propriety of expenditures.

        These matters are presented in more detail in Attachments A through D. Within 60
days, please give us, for each recommendation in the 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.

      If you have any questions, please contact Darrel Vaught, Assistant District Inspector
General for Audit, at (817) 978-9309.

Attachment A - Findings and Recommendations
Attachment B - Schedule of Costs Questioned in 1994 Audit
Attachment C - Background, Scope, and Methodology
Attachment D - Schedule of Questioned Cost Attachment E -
Attachment E - Distribution




                                               2
Attachment A



                                   Findings and Recommendations

Finding 1 - Board’s Action Places Authority in Poor Financial Position

As a result of current and former employee litigation against the Authority for wrongful
termination of employment, the Authority’s financial position has deteriorated and its ability to
continue to administer HUD funded programs may be jeopardized. The Authority, without
obtaining prior HUD approval, paid a court judgment of $115,000 to its current Executive
Director based on her lawsuit over a previous termination. In addition, in 1997 the Authority
agreed to settle, with HUD’s conditional approval, two other former employee lawsuits for
$47,500. Two other lawsuits for about $236,000 are still pending while they are being pursued
through the appellate courts. The Authority is in a precarious financial position. Any use of
HUD funds in payment of the additional settlements or judgments will deplete the Authority’s
financial capacity to the point where it will be unable to adequately house the needy families it
serves.

Since 1993, the Authority management has been in turmoil. As a result, there have been 12
Housing Commissioners and 5 Executive Director changes. One change was made by court
order. Adding to the turmoil, the Authority has been the subject of at least six lawsuits by
former employees involving wrongful firing and “whistle blower” protection. The current
Executive Director, who had been dismissed by a previous Board, filed a lawsuit against the
Authority. As noted in OIG’s interim memorandum, a subsequent Board reappointed her in
February 1996. By entering into an agreed judgment, the Board disregarded HUD’s September
1995 notice that said HUD must give prior approval1 for any settlement or agreement involving
litigation. Although the Board did not obtain prior HUD approval, it also paid the $100,000
judgment. By paying the judgment, the Authority depleted funds normally available for
operations.

Our interim memorandum also noted that the Authority had other pending lawsuits filed by
former employees. On April 7, 1997, HUD Counsel gave approval to the Authority to settle
the cases brought by Ramon Garcia and Jose Martinez for $25,000 and $22,500, respectively.
The approval was conditioned on any budgetary limitations. As of November 1997, the
Authority reported the following status of two remaining cases:

•   Diana Palacios - Judge reversed jury verdict of $26,000, which is on appeal to the Texas
    Third Court of Appeals.

•   Ricardo Lopez - Lower court awarded $210,679, which was reduced by Texas Third Court
    of Appeals to $108,802. The Authority has appealed the case to the Texas Supreme Court.

The latest financial information provided by the Authority shows that it does not have sufficient
unrestricted funds available in its Low Rent or Section 8 Programs to pay these settlements.
Further, as noted in Finding 2, the Authority also continues to incur additional legal costs to
defend itself against these lawsuits.


1
 HUD Handbook 1530.1, Litigation Handbook, requires public housing authorities to obtain prior HUD
approval to settle litigation cases.
The Authority’s independent audit report for the fiscal year ended December 31, 1996, shows
the auditor disclaimed an opinion on the financial statements, in part, because the Authority’s
attorneys did not provide information on the potential liability for pending litigation. The
financial statements also showed the Authority did not have sufficient funds in its HUD
programs, as follows:

                                            Low Rent Program           Section 8 Program            Total
Cash                                        $ (15,061)                 $ 43,334                   $ 28,273
Accounts Receivable                             28,905                                               28,905
Current Assets                              $ 13,844                   $   43,334                 $ 57,178
Less liabilities                               (32,253)                     (8,948)                 (41,201)
Available Resources                         $ (18,409)                 $    34,386                $ 15,9772

The Authority’s Low Rent Statement of Operating Receipts and Expenditures for the 6-month
period ended June 30, 1997, shows the Authority expects to increase its operating reserves by
only about $26,000 in 1997. Further, although the 1995 audit report shows the Authority
increased it Section 8 operating reserves3 by about $22,000 in 1996, the increase was only
$1,100. Therefore, these financial reports show the Authority will not improve its financial
position in 1997.

Recommendations:

We recommend that you:

1A. Closely monitor the litigation against the Authority and, in the event litigants are in a
position to enforce legal judgments against the Authority, exercise HUD’s rights under the
depository agreements to control the accounts and cosign all checks and consider exercising
HUD’s right to take over Authority operations;

1B. Advise HUD Counsel of the precarious financial condition of the Authority and request
they coordinate with your office prior to approving any future settlements of litigation;

1C. Again remind the Board and Executive Director, in writing, that they may not settle any
litigation without obtaining HUD Counsel’s prior approval and, even if Counsel approves,
cannot use HUD funds to pay such settlements or judgments without your express approval;

1D.     Consult with HUD legal counsel to determine whether HUD has a legal basis to: (a)
recover the $115,000 paid to the Executive Director and (b) to impose sanctions against the
parties authorizing and paying the agreed judgment in violation of HUD’s instructions ; and

1E. Pursue administrative sanctions against the Board and Executive Director if they
authorize or participate in the payment of any judgments or settlements without your express
authorization.



2
 The 1996 audit report shows the Authority’s non-HUD Farmers Home Administration project with about
$95,000 in available cash. However, use of such funds would be dependent upon any restrictions or covenants
imposed by that Federal agency.
3
 The increase in operating reserves generally represents the fees collected from HUD less the costs incurred for
administering the Program.
Finding 2 - Authority Did Not Follow HUD Procurement Requirements

The Authority has not followed pertinent requirements in procuring goods and services. It
failed to: (a) provide for free and open competition in selecting vendors; (b) perform a cost or
price analysis prior to award of the contract; (c) use a written contract or purchase order; (d)
incorporate Federally required provisions in the contract; (e) ensure contractors paid the
required prevailing wages on construction contracts; and (f) obtain advance HUD approval
when required. In addition, the Authority did not maintain a contract register to track and
monitor its contracting activity. As a result, HUD and the Authority has no assurance that
contracts complied with applicable laws and regulations and that the amounts paid were
reasonable. We are questioning $102,208 that the Authority used to pay contracts that did not
have Davis-Bacon Act requirements, did not obtain HUD counsel approval, or were in excess
of the adjusted contract price.

HUD Regulations at 24 CFR 85.36 set forth Federal procurement standards that public housing
authorities are to follow. HUD Handbook 7460.8 provides more in-depth guidance to public
housing authorities in adhering to these standards. Because of the Authority’s violation of
these requirements, HUD now requires the Authority to submit all procurements in excess of
$500 to HUD for preaward review and approval. In view of the Authority’s precarious
financial position, it is imperative that the Authority exercise proper control over its
procurements to ensure it is getting needed goods and services at the most reasonable price.

Because the Authority did not maintain a contract register, we identified $855,981 that was
expended for goods and services between May 1993 and June 1996 by reviewing Board
minutes and disbursement records. We reviewed 19 of these procurements representing about
90 percent of the costs. The following shows the total amount by type of procurement:

           Type                              Number           Amount

           Construction                        8             $442,2024
           Professional Service                7              133,398
           Service                     2                87,844
           Purchase                            2              117,335
                   Total                      19             $780,779

HUD’s procurement standards require recipients to maintain records which detail the complete
history of a procurement. Based on review of the Authority’s files for these 19 procurements,
we identified the following exceptions to HUD requirements:




                                                             Professional
                Exception                  Construction        Services        Service      Purchases   Total
    No evidence of competition                     1                4                                     5
    No cost or price analysis                      3                4              2                2    11



4
    One contract for $281,065 was reduced to $199,749. This total is based on the reduced amount.
    No written contract or agreement            2                  1                            2            5
    Did not have all required provisions        6                  3                            na           11
                                         5
    Did not obtain prior HUD approval.                             1              2             1            4

    Did not require prevailing wages            4                 na             na             na           4
    Overpaid the contractor                     1                                                            1


The following violations are sufficient in our view to question the eligibility of costs totaling
$102,208:

           Legal fees paid without prior approval of HUD Counsel

           The Authority entered into a contract on June 2, 1995, with an attorney to handle
           litigation involving the previous termination of the current Executive Director. The
           contract noted the estimated cost of services would be $25,000 and that the contract
           required prior approval by HUD Counsel before the attorney could render and be paid
           for the services from HUD funds. The Authority had no evidence of HUD Counsel’s
           approval of the contract. We are questioning the Authority’s payments of $9,425 to the
           attorney under the contract.

           Prevailing Wages on Construction Contracts

           The Authority used $75,841 to pay construction contractors without ensuring they met
           the prerequisite Federal requirement that they pay prevailing wages. HUD requires
           public housing authorities to follow Davis-Bacon Act provisions for paying prevailing
           construction wages set forth by the U.S. Department of Labor for the locality.
           Therefore, unless the Authority complies with the Act, the use of Federal funds is
           prohibited.

           Authority overpays contractor for renovating units for the handicapped

           The Authority overpaid one of its contractors $16,942. The Authority awarded a
           contract on December 31, 1995, as a unit (quantity) price contract with an estimated
           cost of $281,065. The contract was to make 16 units accessible to the handicapped.
           HUD initially instructed the Authority to rebid this contract because all bids exceeded
           available funding for the work. However, the Authority requested that HUD allow
           funding from future Comprehensive Grant Program funds. The request was based on
           HUD’s requirement that all units identified in its assessment of handicap needs must be
           renovated. Thus, the Authority would be delayed in renovating units because it would
           have to reassess its need for handicap units (to reduce the number of units to meet
           available funding). HUD concurred and allowed the use of the future funding to make
           up the shortfall.

           In April 1995, the Authority decided to reduce the number of units to be renovated from
           16 to 10 because the Authority felt all the units were not needed based on its waiting

5
  HUD’s prior approval is required for contracts that exceed the small dollar threshold ($25,000 until April
1995 when it was increased to $100,000). A June 1, 1995 HUD letter to the Authority told them HUD requires
public housing authorities to obtain prior approval from HUD’s Counsel for legal litigation services contracts
expected to exceed $10,000.
        list. It also felt that the remaining grant funds were needed elsewhere. The contractor
        objected, claiming a reduction would be a breach of contract.6 On June 22, 1995, the
        Authority terminated the contract. On September 20, 1995, the architect informed the
        Authority that the reasonable price of work done under the contract was $182,806.
        Since the Authority had already paid the contractor $199,748, there was an
        overpayment of $16,942. The Authority had not collected this overpayment from the
        contractor. Therefore, we are questioning the eligibility of the $16,942 for HUD
        funding.

Recommendations:

We recommend that you:

2A. Continue the preaward review until such time as the Authority demonstrates it can comply
with HUD procurement requirements and is no longer in weak financial position;

 2B. Require the Authority to either support that the construction contractors paid their
employees the appropriate prevailing wages or require the Authority to repay the HUD
programs $75,841 from non-Federal funds;

2C. Require the Authority to submit its attorney’s contract to HUD Counsel for review and
approval or repay $9,425 to its Low-Rent Program;

2D.    Require the Authority to repay the excess payment of $16,942 to its Comprehensive
Grant Program; and

2E. Review the Authority’s reduction in the number of handicap accessible units to determine
if it violated HUD requirements for the funding and require repayment, if appropriate.




6
 Section 34(b), General Conditions of the Contract for Construction, allows the Authority to terminate the
contract and be liable only for reasonable cost of termination.
Finding 3 - Authority Has Not Resolved All of Questioned Cost from 1994 Audit

The independent public accountant’s audit report on the Authority’s operations for the year
ended December 31, 19947, questioned the propriety of 55 disbursements totaling $26,736
because the costs were not supported by appropriate documentation to show they were
reasonable in amount, properly procured, necessary for Authority operations, or charged to the
proper program. The audit report noted some of the disbursements appeared to be for personal
benefit rather than for proper Authority operations. Based on additional information and
explanations furnished by the Authority’s Executive Director, we concluded that $3,141 was
not proper and another $3,394 needs to be supported by appropriate documentation.

HUD regulations and the accounting handbook require public housing authorities to support the
propriety of their expenditure of public funds with appropriate documentation.8 Further, for
costs to be eligible costs of HUD’s Low Rent and grant Programs, HUD generally requires the
expenditures conform to established Federal cost principles for State and local governments
administering such programs.9

The Authority’s Executive Director provided sufficient information to show a substantial
amount of the costs questioned by the independent auditor were for operations of the
Authority. The following summarizes the results of our review:

          Costs questioned by the independent auditor                                $26,736
          Additional amounts noted by OIG                                              1,025
          Total amount reviewed                                                      $27,761
          Amount Authority supported as eligible                                      21,226
          Amount questioned by OIG (see Attachment B)                                $ 6,535

Recommendations:

We recommend that you:

3A. Instruct the Authority to repay the HUD programs from non-Federal funds the $3,141
disbursed for ineligible items or activities and

3B. Require the Authority to obtain within a reasonable time documentation to support the
propriety of the $3,394 in supported cost and repay the HUD programs from non-Federal funds
any amounts not supported.
1
 The subsequent independent audits for the years 1995 and 1996 did not similarly question operating costs.
Further, our review of disbursements from June 1995 through May 1996 did not disclose similar problems with
documenting the propriety of disbursements.
1
    HUD Regulations at 24 CFR 85 and HUD Handbook RHM 7510.1 (currently HUD Guidebook 7510.1).


7
 The subsequent independent audits for the years 1995 and 1996 did not similarly question operating costs.
Further, our review of disbursements from June 1995 through May 1996 did not disclose similar problems with
documenting the propriety of disbursements.

8
    HUD Regulations at 24 CFR 85 and HUD Handbook RHM 7510.1 (currently HUD Guidebook 7510.1).
9
    Office of Management and Budget Circular No. A-87.
1
    Office of Management and Budget Circular No. A-87.
Attachment B                                                   Schedule of Costs Questioned in 1994 Audit

             Date         Check No.   Amount      OIG Added Ineligible       No Support                    Reason Questioned
                 09/16/94     15837 $    425.95   $         $    64.22      $              Local meals
                 09/16/94     15837                                               82.88    Reimbursement - no receipts
                 02/10/94     14389      275.00                    275.00                  Purchase of jeweld pins as gifts
                 02/17/94     14450      104.44                                   30.61    Reimbursement - no receipts
                 11/08/94     16130       48.75                                   30.75    Travel - Advance in excess of allowance - no receipts
                 08/19/94     15660      167.80                                   79.00    Travel - Advance in excess of allowance - no receipts
                 07/28/94     15496       92.80                                   34.66    Travel - Advance in excess of allowance - no receipts
                 12/29/94     16423      209.46                                  122.12    Reimbursement - no receipts
                 03/20/94     14625      635.70                    363.93                  Travel - movies, meals, gifts charged to Authority credit card
                 08/19/94     15657      428.67                     67.57                  Reimbursement - not for Authority operations
                 12/22/94     16390    2,391.65                    731.35                  Purchase of Christmas Decorations
                 12/22/94     16390                                              984.21    Purchase - receipt does not identify item
                 11/30/94     16271      482.98                    163.07                  Purchase of Christmas Decorations
                 11/30/94     16271                                              165.84    Reimbursement - no reciepts
                 11/16/94     16216      297.39                                  119.12    Reimbursement - no reciepts
                 02/03/95     16646      441.17                                  120.53    Reimbursement - no reciepts
                 10/09/94     15970      413.35                                   31.29    Reimbursement - no reciepts
                 01/13/94     14188      541.25                    523.25                  Travel - Advanced to cover travel for excessive stay
                 03/10/94     14526      511.75                    390.75                  Travel - Advanced to cover travel for excessive stay
                 03/23/94     14610      187.00                    125.00                  Travel - Taxi trips not related to conference attended
                 04/28/94     14869       73.00                     65.00                  Travel - Advanced to cover travel for excessive stay
                 04/28/94     14969      292.36                                   88.60    Reimbursement - no reciepts
                 03/23/94     14611      370.63                                  370.63    Cellular telephone calls - business purpose not shown
                 06/08/94     15206      650.80                    126.00                  Travel - Advanced to cover travel for excessive stay
                 10/18/94     16032       50.00      467.80        191.00                  Travel - Advanced to cover travel for excessive stay
                 10/18/94     16032                                                50.00   Travel - Advanced for taxi trips - no receipts
                 02/13/94     16680       50.00                                    50.00   Travel - Advanced for taxi trips - no receipts
                 08/08/94     15606       43.25                     43.25                  Travel - Amount of meal charged to Authority credit card
                 04/06/94     14712       24.25      208.50                      232.75    Travel - Advance not supported by any other documents
                 06/01/94     15189      405.00                                  151.00    Travel - Advanced in excess of allowance - no receipts
                 06/03/94     15197       92.80                                   40.00    Travel - Advanced for parking - no receipts
                 03/10/94     14527                  300.00                      233.31    Travel - Advanced in excess of allowances - no receipts
                 03/10/94     14528      352.80                                  233.31    Travel - Advanced in excess of allowances - no receipts
                 06/01/94     15190       70.48                     12.00                  Travel - Advanced for meals in excess of allowance
                 06/27/94     15343       77.80                                    25.00   Travel - Advanced for meals not supported by receipts
                 11/18/94     16224       40.00                                    40.00   Travel - Advanced for meals not supported by receipts
                 03/10/94     16818       99.80                                    47.00   Travel - Advanced for meals/parking not supported by receipts
                 11/08/94     16131                    48.75                       30.75   Travel - Advanced for meals in excess of allowance
     Questioned by OIG              $ 10,348.08   $ 1,025.05   $ 3,141.39   $   3,393.36
     Not Questioned by OIG            15,187.83
     Total Questioned in            $ 26,735.91
         Audit
Attachment C

                                         BACKGROUND

A five-member Board of Commissioners governs the Housing Authority of the City of Crystal
City, Texas. The Mayor of Crystal City appoints the Board members. The Board is responsible
for setting policy and hiring an Executive Director to administer the day-to-day operations of
the Authority. Since 1993, the Authority’s Board has changed 12 times and the Authority has
had 5 Executive Directors. The Authority's office is located at 1600 N. 7th Avenue, Crystal
City, Texas.

The Authority has 288 units of low rent housing and is authorized to provide Section 8 housing
assistance for 200 units. The Authority also administers a separate project originally funded by
the Farmers’ Home Administration. In addition to rental revenues, HUD provides the
Authority an annual operating subsidy of over $300,000 and Comprehensive Grant Program
funds for modernizing units of around $350,000 per year.


                                SCOPE AND METHODOLOGY

The review objectives were to determine whether the Authority: (1) had the financial resources
to satisfy pending litigation with current and former employees; (2) procured goods and
services in a manner providing free and open competition free of any conflicts of interest; (3)
improperly paid Section 8 rental assistance to owners for vacant units, or to local officials
having a conflict of interest, or to landlords that were selling the property to the recipient; and
(4) properly expended funds questioned by its independent public accountant’s 1994 audit
report. To accomplish these objectives we obtained background information by:

• Reviewing relevant HUD regulations and guidelines, Annual Contributions Contracts for
 Low-Rent and Section 8 Existing Programs, HUD San Antonio Office of Public Housing
 records including monitoring reports and Authority submitted reports, and the three most
 recent independent audit reports, and

• Interviewing HUD and Authority staff to gain an understanding of Authority operations,
 management control practices, and explanations regarding the independent auditor’s
 questioned costs.

To evaluate the Authority’s financial position, we reviewed the Authority’s financial records,
financial and audit reports to HUD, and correspondence regarding the status of various lawsuits
filed by current and former employees.

To evaluate the Authority’s procurement practices, we:

• Identified its contracting activities by reviewing Board minutes and disbursement records, as
 well as interviewing Authority staff;

• Reviewed the Authority’s adopted procurement policy and compared it to HUD
 requirements;
• Selected 19 procurements of goods and services and reviewed the Authority’s records
 documenting the procurements including the methods of solicitation and award.
To determine if the Authority improperly paid Section 8 rental assistance to owners for vacant
units, to local officials having a conflict of interest, or to landlords that were selling the property
to the recipient, we:

• Interviewed Authority staff;
• Compiled a list of local officials;
• Randomly selected a sample of 182 Section 8 tenants, scanned the files, and compared the
  information to the list of local officials;
• Performed unit inspections and interviewed tenants and landlords as necessary; and
• Reviewed county tax and deed records as well as interviewed the County Tax Appraiser.

To determine if the independent auditor’s questioned disbursements were proper and whether
subsequent disbursements were properly documented, we:

• Interviewed Authority staff;
• Obtained and reviewed available supporting documentation;
• Reviewed corroborating documents (registration forms, etc.) for travel to conferences;
• Randomly selected a sample of 1,948 checks written between June 1, 1995, and May 31,
  1996, and examined the supporting documentation; and
• Reviewed the findings in the 1995 and 1996 independent auditor reports to determine if they
  also had similar questioned costs.

Our review was primarily conducted from May 1996 to May 1997, with some additional review
regarding the status of the latest financial and audit reports on file with the HUD San Antonio
Office during the period October 1997 through January 1998.
Attachment D

Schedule of Questioned Costs


                      Recommendation
                          Number                        Ineligible10             Unsupported11

                              1D                                                     $115,000
                              2B                                                       75,841
                              2C                                                        9,425
                              2D                        $16,942
                              3A                          3,141
                              3B                                                          3,394
                             TOTALS                     $20,083                       $203,660

1
    Costs clearly not allowed by law, contract, HUD, or local agency policies or regulations.

2
    Costs not clearly eligible or ineligible but which warrant being contested (e.g., lack of satisfactory documentation to
    support the eligibility of the cost, etc.).




1
    Costs clearly not allowed by law, contract, HUD, or local agency policies or regulations.

2
    Costs not clearly eligible or ineligible but which warrant being contested (e.g., lack of satisifactory documentation to
    support the eligibility of the cost, etc.).
Attachment E

                                     DISTRIBUTION

Secretary's Representative, 6AS
State Coordinator, 6JS
Comptroller, 6AF
Director, Accounting, 6AAF
Director, Public Housing, 6JPH (4)
Dwight P. Robinson, Deputy Secretary, SD (Room 10100)
Hal C. DeCell III, A/S for Congressional and Intergovernmental Relations, J (Room 10120)
Karen Hinton, A/S for Public Affairs, W (Room 10132)
Jon Cowan, Chief of Staff, S (Room 10000)
Robert Hickmott, Counselor to the Secretary, S (Room 10234)
Patricia Enright, Sr Advisor to the Secretary for Communication Policy, S (Room 10222)
Gail W. Laster, General Counsel, C (Room 10214)
Saul N. Ramirez, Jr., Assistant Secretary for CPD, D (Room 7100)
Marilynn A. Davis, Assistant Secretary for Administration, A (Room 10110)
Nicolas P. Retsinas, Assistant Secretary for Housing, H (Room 9100)
Kevin Marchman, Acting A/S for Public & Indian Housing, P (Room 4100)
Assistant to the Deputy Secretary for Field Management, SDF (Room 7106)
Assistant to the Secretary for Labor Relations (Acting), SL (Room 7118)
Public Housing ALO, PF (Room 5156) (3)
Chief Financial Officer, F (Room 10164) (2)
Deputy Chief Financial Officer for Operations, FF (Room 10166) (2)
Director, Hsg. & Comm. Devel. Issues, US GAO, 441 G St. NW, Room 2474
 Washington, DC 20548 Attn: Judy England-Joseph
Mr. Pete Sessions, Govt Reform & Oversight Comm., U.S. Congress,
 House of Rep., Washington, D.C. 20515-4305
The Honorable Fred Thompson, Chairman, Comm. on Govt Affairs,
 U.S. Senate, Washington, D.C. 20510-6250
The Honorable John Glenn, Ranking Member, Comm. on Govt Affairs,
       U.S. Senate, Washington, D.C. 20510-6250
Cindy Sprunger, Subcomm. on Gen. Oversight & Invest., Room 212,
       O'Neill House Ofc. Bldg., Washington, D.C. 20515
Inspector General, G
Auditee