oversight

Congressional Request, Cascade Inter-Tribal Housing Authority Sedro Woolley, WA

Published by the Department of Housing and Urban Development, Office of Inspector General on 1998-01-30.

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

                           Audit Report
                           District Inspector General for Audit
                           Northwest/Alaska District
                           Report: 98-SE-207-1001            Issued: January 30, 1998


TO:             Jeanne C. McArthur, Acting Administrator, Northwest Office of Native
                American Programs, 0API


FROM:           A. George Tilley, District Inspector General for Audit, OAGA

SUBJECT: Congressional Request
         Citizen Complaint
         Cascade Inter-Tribal Housing Authority
         Sedro Woolley, WA

We performed an audit at the Cascade Inter-Tribal Housing Authority (Housing
Authority) to evaluate allegations in a complaint received through the office of
Congressman Jack Metcalf of the United States House of Representatives. The
complainant alleged fraud, waste, and mismanagement at the Housing Authority in
the areas of:

      • procurement,
      • use of Comprehensive Improvement Assistance Program (CIAP) grant
          funds,
      •   travel,
      •   the award of Section 8 Vouchers and Mutual Help homes,
      •   calculation of payments for Mutual Help homes, and
      •   maintenance of Mutual Help homes.

We did not substantiate the allegations in the complaint relating to procurement,
use of CIAP grant funds, and travel. However, we determined that the allegations
relating to the award of a Section 8 Voucher and a Mutual Help home, calculation of
payments for Mutual Help homes, and maintenance of Mutual Help homes were
valid.

As provided in HUD Handbook 2000.6 REV-2, within 60 days, please provide us, for
each recommendation in this report, a status report on: (1) the corrective action
                                                                       98-SE-207-1001


taken; (2) the proposed corrective action and the date to be completed; or (3) why
action is considered unnecessary. Also, please furnish us copies of any
correspondence or directives issued because of this review.

A copy of this report has been provided to the Housing Authority and the office of
Congressman Jack Metcalf.

If you have any questions, please call Robert Woodard or Jerrald Hite at
(206) 220-5360.




                                                                                     ii
                                                          98-SE-207-1001



Executive Summary
We performed an audit at the Cascade Inter-Tribal Housing Authority
(Housing Authority). Our audit objective was to evaluate allegations in a
complaint received through the office of Congressman Jack Metcalf of the
United States House of Representatives. The complainant alleged fraud,
waste, and mismanagement at the Housing Authority in the areas of:

• procurement,
• use of Comprehensive Improvement Assistance Program (CIAP)
    grant funds,
•   travel,
•   the award of Section 8 Vouchers and Mutual Help homes,
•   calculation of payments for Mutual Help homes, and
•   maintenance of Mutual Help homes.

We did not substantiate the allegations in the complaint relating to
procurement, use of CIAP grant funds, and travel. We did determine that
the Housing Authority was not following all of their procedures and lacked
some required documentation in these areas. However, the deficiencies
identified did not have any negative impact on the Housing Authority’s
programs.

We found that the allegations relating to the award of one Section 8
Voucher and one Mutual Help home, calculation of payments for Mutual
Help homes, and maintenance of Mutual Help homes were valid. We
confirmed:

• improper award of a Section 8 Voucher, and a Mutual Help home to the
  same family member of both the former Executive Director and former
  Housing Authority Board Chairman;
• underreporting of income, payments lower than required, and profiting
  from unapproved subleases for Mutual Help homes of the former
  Executive Director, her family, and a friend; and
• unrepaired health and safety hazards in occupied and vacant Mutual
  Help homes.

We concluded that the Housing Authority Board of Commissioners
(Board), which included the former Executive Director’s father, did not
adequately carry out their oversight responsibilities over the Housing
Authority, and in our opinion this lack of oversight contributed to the
deficiencies identified in our audit.



                                                                          iii
                                                          98-SE-207-1001



We also concluded that the former Executive Director took advantage of
her position to provide favored treatment to herself, her family members,
and a friend. The former Executive Director did not ensure that income
recertifications and payment calculations were accurate, Mutual Help
homes were properly maintained, and vacant Mutual Help homes were
repaired and awarded to eligible homebuyers.

On December 5, 1997, we provided a draft of this report to the Interim
Board for their comments. The Housing Authority provided us their
comments in a letter dated December 12, 1997. We incorporated
portions of their comments in this report as we determined appropriate
along with our evaluation. The Housing Authority’s comments are
included in their entirety in Appendix 1.

Our audit scope was limited due to a lack of documentation and
unavailability of individuals involved to discuss information obtained and
conclusions reached during our audit. In this regard, we presented our
draft report to the former Executive Director and former Board Chairman
on January 9, 1998. The former Executive Director and former Board
Chairman read the draft report and chose not to make any comments or
answer any questions about the results of our audit.




                                                                             iv
                                                                          98-SE-207-1001



Table of Contents
Management Memorandum .........................................................i

Executive Summary.................................................................... iii

Table of Contents ........................................................................v

Introduction ................................................................................. 1

Results

    Three of Six Allegations of Fraud, Waste, and
    Mismanagement Were Valid ................................................. 4

    A. Unsubstantiated Allegations.............................................. 5
    B. Valid Allegations................................................................ 8
    C. Conclusion ...................................................................... 24
    D. Actions Taken By The Tribes .......................................... 25
    E. Auditee Comments and OIG Evaluation ......................... 26
    F. Recommendations .......................................................... 27

Internal Controls ....................................................................... 29


Appendices

    1. Auditee Comments.......................................................... 30
    2. Distribution ...................................................................... 40

Abbreviations

HUD              Department of Housing and Urban Development
CIAP             Comprehensive Improvement Assistance Program
NAHASDA          Native American Housing and Self Determination Act
CFR              Code of Federal Regulations




                                                                                              v
                                                          98-SE-207-1001



Introduction
The Cascade Inter-Tribal Housing Authority (Housing Authority) currently
operates federally assisted low income housing for the Upper Skagit
Indian Tribe and the Sauk Suiattle Indian Tribe. The Housing Authority
currently manages a total of 70 Mutual Help homes and 118 Section 8
Vouchers. In addition, the Housing Authority has received
Comprehensive Improvement Assistance Program (CIAP) grants of
$325,000 in 1993; $1,335,285 in 1995; and $663,310 in 1996. HUD
awarded these grants to make physical improvements to the Mutual Help
homes and management improvements for the Housing Authority.

In July 1997, based on information brought to the attention of the Upper
Skagit Tribe’s General Manager and Controller by Housing Authority staff,
the former Executive Director was relieved of her position at the Housing
Authority. In addition, after the former Executive Director was relieved of
her position, the members of the Board were removed by the Tribes and
an Interim Board was put in place made up of members of the Tribal
Councils.

The Upper Skagit and Sauk Suiattle Tribes are currently in the process of
separating their housing operations due to the new Native American
Housing and Self Determination Act (NAHASDA). This will result in the
dissolution of the Housing Authority as it currently exists. These changes
by the Tribes were taken into consideration when developing the
recommendations for this report.

Audit Objectives

We performed audit work at the Housing Authority to evaluate the validity
of allegations in a complaint received through the office of Congressman
Jack Metcalf of the United States House of Representatives. The
complainant alleged fraud, waste, and mismanagement at the Housing
Authority in the areas of procurement, use of CIAP grant funds, travel, the
award of Section 8 Vouchers and Mutual Help homes, calculation of
payments for Mutual Help homes, and maintenance of Mutual Help
homes.




                                                                        1
                                                         98-SE-207-1001


Audit Scope

The audit work covered events and transactions at the Housing Authority
from January 1, 1993 through August 22, 1997 as we considered
necessary to achieve our objectives and address issues in the complaint.
The audit work covered the Housing Authority’s Section 8 Voucher,
Mutual Help Homeownership, and CIAP programs.

Our audit scope was limited as follows:

• The Housing Authority did not have all required documentation to
  demonstrate compliance with Mutual Help requirements. Files
  generally lacked information verifying family income used in payment
  computations. Files also generally lacked documentation supporting
  decisions for the award of Section 8 Vouchers and Mutual Help homes.

• Section 8 and Mutual Help files did not contain required income
  release forms which restricted our ability to verify employment and
  income information necessary to determine compliance. In the
  absence of this information we relied upon information obtained from
  the other sources and made certain assumptions in our calculations as
  described in our findings.

• Homebuyers and a certain former Housing Authority staff member were
  either unavailable, or declined the opportunity to discuss the
  information obtained and conclusions we reached in our audit.

• The former Executive Director was unavailable while we were on site.
  However, she and her father, the former Board Chairman, agreed to
  meet with us on January 9, 1998. At this meeting the former Executive
  Director, and the former Board Chairman, read the draft report and
  then informed us that they did not want to make any specific comments
  relating to the information in the report and did not want to answer any
  questions. They stated that they felt their best course of action was to
  let the audit process take its course.

Audit work was performed at the Housing Authority offices in Sedro
Woolley, WA, and both the Upper Skagit and Sauk Suiattle Mutual Help
developments. Audit work was performed from August 1997 through
November 1997.




                                                                       2
                                                           98-SE-207-1001


Audit Methodology

To achieve our audit objectives we:

•   Obtained, reviewed, and summarized legislative, regulatory, and
    contractual requirements for the programs operated by the Housing
    Authority.

•   Reviewed HUD and Housing Authority documents, and interviewed
    HUD and Housing Authority staff, and:

    → obtained an understanding of the programs operated by the
      Housing Authority.

    → gained an understanding of control systems at the Housing
      Authority and assessed the risk associated with those systems for
      the purposes of developing audit procedures.

•   Interviewed current and former Housing Authority staff, and residents
    of Mutual Help homes to obtain their perspective, and any additional
    comments or information relating to events identified in the complaint.

•   Reviewed HUD and Housing Authority documents relating to audit
    objectives.

•   Inspected 17 of the Housing Authority’s 70 Mutual Help homes.
    Homes were selected based on information in the complaint.

•   Performed other procedures as determined necessary based on
    information obtained during the audit.

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




                                                                         3
                                                       98-SE-207-1001



Results
  THREE OF SIX ALLEGATIONS OF FRAUD, WASTE AND
           MISMANAGEMENT WERE VALID

We performed our audit to evaluate the validity of allegations citing
fraud, waste, and mismanagement at the Housing Authority in the
areas of:
    • procurement,
    • use of Comprehensive Improvement Assistance Program
       (CIAP) grant funds,
    • travel,
    • the award of Section 8 Vouchers and Mutual Help homes,
    • calculation of payments for Mutual Help homes, and
    • maintenance of Mutual Help homes.

We did not substantiate the allegations in the complaint relating to:
   • procurement,
   • use of CIAP grant funds, and
   • travel.

We did determine that the Housing Authority was not following all of
their procedures and lacked some required documentation in these
areas. However, the deficiencies identified did not have any negative
impact on the Housing Authority’s programs.

We found that the allegations relating to award of one Section 8
Voucher and one Mutual Help home, calculation of payments for
Mutual Help homes, and maintenance of Mutual Help homes were
valid. We confirmed:

   • improper award of a Section 8 Voucher, and a Mutual Help
     home to the same family member of both the former Executive
     Director and former Housing Authority Board Chairman;
   • underreporting of income, payments lower than required, and
     profiting from unapproved subleases for Mutual Help homes
     of the former Executive Director, her family, and a friend; and
   • unrepaired health and safety hazards in occupied and vacant
     Mutual Help homes.




                                                                    4
                                                            98-SE-207-1001


We concluded that the Board, which included the former Executive
Director’s father, did not adequately carry out their oversight
responsibilities over the Housing Authority, and in our opinion this
lack of oversight contributed to the deficiencies identified in our
audit.

We also concluded that the former Executive Director took
advantage of her position to provide favored treatment to herself, her
family members, and a friend. In addition, the former Executive
Director did not ensure that income recertifications and payment
calculations were accurate, Mutual Help homes were properly
maintained, and vacant Mutual Help homes were repaired and
awarded to eligible homebuyers.


A. UNSUBSTANTIATED ALLEGATIONS
Unsubstantiated allegation regarding procurement

The complainant alleged that some contracts for construction work
procured by the former Executive Director were given to contractors who
then gave work to the Executive Director’s husband.

What the criteria requires

HUD regulations at 24 CFR 905, Subpart B covered the area of
procurement for Indian Housing Authorities until they were replaced on
May 10, 1995 by 24 CFR 950, Subpart B.

The Housing Authority has a procurement policy that does comply with
procurement regulations. This policy calls for maintaining a record to
detail the history of procurements, procurement using full and open
competition, and ensuring that a prequalified list of firms is current and
includes enough sources for such open competition. The Housing
Authority procedures also states that it is the responsibility of the
Executive Director or someone assigned the duties of contracting to
administer the policies in accordance with the regulations.

What we concluded

We concluded that there is no evidence available to substantiate the
allegation that some contracts for construction work were given to
contractors who then gave work to the former Executive Director’s
husband.



                                                                             5
                                                          98-SE-207-1001



We interviewed the complainant as well as current and former Housing
Authority employees to obtain information on specific instances where the
husband of the former Executive Director may have received work from
Housing Authority contracts. None of the individuals were able to provide
specific information.

In the absence of specific information on the allegation we interviewed the
current Housing Authority employee responsible for procurement and the
prior two Housing Authority employees responsible for procurement. One
of the prior employees also served as a consultant to the Housing
Authority for procurement after leaving his position as Executive Director.
In addition, we reviewed current Housing Authority procurement policies
and procedures and determined that they do comply with HUD
requirements.

According to current and former employees interviewed, they maintained
files documenting their procurements by the Housing Authority. A current
employee stated that some Housing Authority procurement files cannot be
located. Our review of the files available at the Housing Authority
confirmed that there was little historical documentation supporting
procurement by the Housing Authority.

According to the former employees interviewed, the former Executive
Director did not do much procurement. Current employees stated that the
former Executive Director did procure work for fixing windows. The
Housing Authority’s accountant stated that almost all the work done for
window repair was completed by Sedro Woolley Glass. In a telephone
discussion with a representative from Sedro Woolley Glass, he stated that
he completed the work done on the reservation. He stated that someone
from the Housing Authority would call, he would measure the window,
give a bid, and then he would do all the work if he got the job.


Unsubstantiated allegation regarding the use of CIAP grant
funds

The complainant alleged that the Housing Authority had a large amount of
money that needed to be spent or they would lose it, and therefore the
Housing Authority purchased appliances that were not needed and they
were given to friends and relatives of the former Executive Director.




                                                                        6
                                                         98-SE-207-1001


What the criteria requires

Federal regulations at 24 CFR 905 Subpart I and 950 Subpart I
implements the Comprehensive Improvement Assistance Program for
Indian Housing Authorities. This program provides for grants to Indian
Housing Authorities for physical improvements to the Mutual Help homes
and management improvements for the Housing Authorities.

Regulations at 24 CFR 950.614 states that all approved funding must be
obligated within two years of approval and expended within three years
unless HUD approves a longer time period.

According to 24 CFR 950.634, CIAP funds are required to be used for
purposes that HUD originally approves or in accordance with a revised
CIAP budget.

What we concluded

The audit results do not substantiate the allegation that unneeded
appliances were purchased and given to friends and relatives of the
former Executive Director.

Housing Authority records show that they prepared lists of homes that
needed appliances including ranges, refrigerators, and water heaters.
The lists excluded those residents that had recently purchased
appliances. The approved CIAP budget included the purchase of these
appliances. The Housing Authority drew down $120,000 on their 1995
CIAP Grant in April 1996 and used $74,000 of these funds to purchase
the appliances according to the lists prepared. Some residents not on the
list had already purchased new refrigerators before the CIAP award, and
therefore there were some disgruntled families who believed that this was
unfair treatment. One of the families that had purchased a refrigerator
was the former Executive Director.

A May 1997 HUD review of the Housing Authority’s 1995 CIAP grant
contains a finding that the Housing Authority’s April 1996 $120,000
drawdown exceeded their immediate needs and that in fact they had only
expended $75,042.50 of the funds. HUD required the Housing Authority
to submit a plan to expend the remainder of the drawdown and restricted
them from any additional drawdowns until the balance of the $120,000
was expended.


Unsubstantiated allegation regarding travel




                                                                        7
                                                         98-SE-207-1001


The complainant alleged that the former Executive Director would travel
first class when going to training and seminars.

What the criteria requires

The Housing Authority maintains a policy manual which contains a travel
section as required by HUD regulations. These policies list the
requirements when a staff member or Board member of the Housing
Authority is on travel status. These policies state that the Executive
Director is responsible for approving travel of staff members. The
Executive Director is responsible for authorizing travel expense
reimbursement unless it is their own travel expense form. In this case,
the Board Chairperson is to authorize expenses. When submitting
expense forms, airline and hotel receipts are required.

What we concluded

We concluded that the Housing Authority staff followed policies and
guidelines established to regulate the use of travel funds on purchase of
tickets at the most economical rate. According to documents maintained in
files, the amounts paid by the Housing Authority for airline tickets were
consistent with economy class fares.




B. VALID ALLEGATIONS
Valid allegation regarding family favoritism by the former
Executive Director when awarding a Section 8 Voucher and
Mutual Help home

Allegations stated that the former Executive Director gave favored
treatment to her friends and family when awarding Section 8 Vouchers
and Mutual Help homes. According to the allegations, family members
and friends of the former Executive Director moved ahead of others on
the Section 8 and Mutual Help waiting lists and received Section 8
Vouchers and Mutual Help homes when they were not eligible.

What the criteria requires

The regulations for the Section 8 Voucher program at 24 CFR 887.1 state
that the Section 8 Voucher program is intended to assist eligible families
to pay rent for decent, safe, and sanitary housing. Federal regulations at
24 CFR 813.103 restricts participation in the Section 8 Voucher program
to low-income families. Regulations at 24 CFR 887.61 require the


                                                                        8
                                                                  98-SE-207-1001


Housing Authority to establish policies for maintaining, closing, and
reopening waiting lists.

Regulations governing the operations of Indian Housing programs were
published at 24 CFR 905 until they were replaced by 24 CFR 950 in May
1995. Regulations at 24 CFR 905 Subpart E and 950 Subpart E
implemented a low income homeownership program called the Mutual
Help program. The program requirements at 24 CFR 905.416 and
950.416, limit eligibility for participation in the Mutual Help program to low
income families unless special circumstances are met and HUD approval
is obtained. Regulations at 24 CFR 905.301 and 950.301 require the
Housing Authority admission policies to include requirements for waiting
lists.

Both 24 CFR 905 and 950 were eliminated as of September 30, 1997. As
of October 1, 1997 the new Native American Housing and Self
Determination Act took effect. This new Act is the basis for all HUD
Native American Housing programs. Our review covered events that
were prior to October 1, 1997 and were therefore governed by 24 CFR
905 and 950.

What we concluded

The former Executive Director awarded a Section 8 Voucher to her sister
and her family who made more money than allowed by the Section 8
program and were 16th on the waiting list.

We reviewed four of the seven Section 8 Vouchers and one of the three
Mutual Help homes awarded during the former Executive Director’s
tenure. These awards were selected based on information from Housing
Authority staff indicating a relationship between the recipient and the
former Executive Director.

Of the four Section 8 Vouchers reviewed, three were properly awarded.
However, the former Executive Director awarded a Section 8 Voucher to
her sister and her family in November 1996, after the prior Section 8
Coordinator had rejected them as ineligible. At the time of the award,
according to income information received from the State of Washington,
the sister and her husband were not eligible for the Section 8 program.
According to State records they earned $31,758 in 1996 and continued
work into 1997 with income of $5,915 in the first quarter of 1997.1 This


1
  The Housing Authority did not have required income releases. The employer for the
sister and her husband did provide us with confirmation of employment. However, the
employer would not provide any information to us on salary without a release.



                                                                                  9
                                                                  98-SE-207-1001


projects to an annual income of $23,660 for 1997. These income levels
are in excess of the $16,900 limit for a family of 3 to participate in the
Housing Authority’s Section 8 program in Skagit County. In addition, the
sister and her family were 16th among Upper Skagit Tribal members on
the Section 8 waiting list.

The previous Section 8 Coordinator for the Housing Authority (prior to
October 1996) stated that she did not approve the Section 8 Voucher for
the sister and her family because the sister stated that her brother would
be living in the household and no income information was submitted for
the brother. The approved Section 8 housing lease does not include the
brother as a member of the household. Documentation in the Section 8
file shows that no current income documentation was obtained for any
household member at the time the Voucher was approved. The only
support for any of the income calculations was pay stubs for the sister
and her husband for the weeks ended December 21, 1995 and January 4,
1996; nearly one year prior to the approval of the Voucher. In addition,
there is no justification in the file showing how or why the sister and her
family were moved ahead of 15 families on the waiting list to receive their
Voucher.

Six months after the former Executive Director’s sister and her family (also
the daughter of the former Board Chairman) received a Section 8
Voucher, the Board, based on information provided by the former
Executive Director, awarded them a Mutual Help home.

In May 1997, the Board awarded a Mutual Help home to the former
Executive Director’s sister and her family (also the daughter of the former
Board Chairman). This family was not the next eligible applicant on the
Mutual Help waiting list, and had family income over the limit for the
program. According to HUD records and Housing Authority staff, the
Housing Authority has never requested or received approval for over-
income participation in their Mutual Help program. The award was based
on information presented to the Board by the former Executive Director
identifying the family as eligible.

Documents in the Housing Authority’s Mutual Help file for this home
indicate that in May 1997 the sister and her family requested a Mutual
Help home because it would be more beneficial due to her family income.
At the time of this request the sister and her family were 18th on the
Mutual Help waiting list overall, and 11th on the waiting list for those
wanting a two bedroom home. According to Board minutes only 5 of the
top 11 applicants for two bedroom homes, including the sister and her

Therefore, we used income information received from the State of Washington as the
basis for our calculations.



                                                                                     10
                                                          98-SE-207-1001


family, were discussed. There was no indication why the other six were
not discussed. Also, Board minutes did not explain why one of the other
applicants who was higher on the waiting list and met the Board’s
requirement of having their account with the Housing Authority cleared
up, was not awarded the house.

Income information was not submitted to the Board. However, at the time
the sister and her family were awarded the home, the family income,
according to income information received from the State of Washington,
was projected to be $23,660. At that time the income limits used by the
Housing Authority to determine income eligibility limited income to
$16,900. Therefore, based on the State’s income information, the sister
and her family were not eligible to participate in the Mutual Help program.

In addition to the sister and her family not being eligible for the home,
Board approval for this family contradicts previous decisions by the Board
for similar cases. Review of Board minutes shows that for several
previous Mutual Help applicants that were participating in the Housing
Authority’s Section 8 program, the Board required the applicants to
complete their lease term before being approved for a Mutual Help home.
There is no information available to explain why this position was not
taken in this case.


Valid allegation regarding the former Executive Director and
members of her family not reporting all of their income and
paying less than required for their Mutual Help homes

The complainant alleged that the former Executive Director improperly
calculated her own payment on her Mutual Help home and also gave
favored treatment when calculating payments for members of her family
and friends that live in other Mutual Help homes. The complainant also
alleged that all income was not reported for the former Executive Director
and family members that are also Mutual Help homebuyers.




                                                                        11
                                                        98-SE-207-1001


What the criteria requires

Regulations at 24 CFR 905 and 950 Subpart E implemented a low income
homeownership program called the Mutual Help program. The program
requirements at 24 CFR 905.416 and 950.416, limit eligibility for
participation in the Mutual Help program to low income families unless
special circumstances are met and HUD approval is obtained. Mutual
Help monthly house payments are based on the income of the participant
family with a minimum monthly administrative fee and a maximum monthly
payment established by the Housing Authority. Regulations require the
Housing Authority to certify participants’ income at least annually.

Housing Authority policies require annual recertifications and interim
recertifications if the homebuyers income or family composition changes.
If a homebuyer does recertify mid year and their payment goes down,
they are then required by Housing Authority policy to recertify when any
change occurs that would increase their payment. Housing Authority
policy also requires retroactive implementation of any payment increase.
Any payment increase will be effective on the first day of the second
month after the change occurred that caused the increase.

The requirements for reporting income and calculating monthly payments
also apply to individuals subleasing Mutual Help homes. Subleases are
currently allowed in the Mutual Help program under the terms of the
Mutual Help Occupancy Agreement between the homebuyer and the
Housing Authority. The terms of this agreement require prior written
approval of the sublease by the Housing Authority. In addition, the
sublease requirements state that the homebuyer remains responsible for
the required monthly payment to the Housing Authority.

What we concluded

We could not determine from Housing Authority records if the former
Executive Director improperly calculated Mutual Help payments.
However, we did determine that family income for five of the nine Mutual
Help homebuyers reviewed, including the former Executive Director,
members of her family, and a friend, was either underreported or
understated. As a result, these five Mutual Help homebuyers were paying
less than required for their Mutual Help homes; and in some cases were
receiving inappropriate benefits from subleasing their Mutual Help homes
without Housing Authority approval.

We reviewed the payment calculations for 9 of the 63 Mutual Help
homebuyers. These homebuyers were selected for review based on




                                                                      12
                                                           98-SE-207-1001


information from Housing Authority staff that indicated a relationship to
the former Executive Director.

      Improper calculation of Mutual Help payments

      According to current Housing Authority staff, all Mutual Help
      payment calculations required the review of the former Executive
      Director. However, of the 24 payment calculations we reviewed,
      only 4 were signed by the former Executive Director, and 13 were
      not signed by a Housing Authority Representative. Without a
      signature by a Housing Authority Representative, we could not
      determine who performed the calculations. Of the 13 calculations
      that were not signed, 10 were on Housing Authority payment
      calculation forms that did not require the signature of a Housing
      Authority Representative.

      The 24 payment calculations we reviewed included 7 payment
      calculations for the former Executive Director. All seven of these
      payment calculations were signed by the former Executive Director
      as the homebuyer. Only the three most recent payment
      calculations for the former Executive Director were signed by a
      Housing Authority Representative. The former Executive Director
      did not sign any of her own payment calculations as a Housing
      Authority Representative.

      Family Income

      Our review indicates that these Mutual Help homebuyers’ income
      used in the Housing Authority’s payment calculations were
      understated. As a result they received an inappropriate financial
      benefit because their required monthly payments were lower than
      they should have been. Of the 24 payment calculations we
      reviewed to address the allegations, 13 were not signed by a
      Housing Authority representative and therefore, we could not
      determine who performed the calculation. However, according to
      current and former Housing Authority staff, all Mutual Help
      payment calculations required the review of the former Executive
      Director.

      These lower monthly payments also have a negative financial
      impact on the Housing Authority. The additional amounts that
      these homebuyers should have made would be deposited into
      homebuyer equity accounts. These funds serve as security
      deposits for the homes. The funds in equity accounts are available
      to make repairs to the homes by the homebuyer if they cannot



                                                                            13
                                                                     98-SE-207-1001


        afford to repair certain items. In addition, the Housing Authority
        may use funds in the equity accounts to repair the home if the
        home becomes vacant, or the homebuyer does not properly
        maintain it.

                The Former Executive Director underreported her family
                income

                The former Executive Director did not report all family
                income to the Housing Authority on two occasions. In June
                1995 the former Executive Director reported her husband’s
                income at zero when, according to State employment
                records2, he received income during that quarter. This
                reduced the families Mutual Help payment by $70.00 per
                month for 16 months, until their payment was recalculated in
                October 1996. In July 1997, the former Executive Director
                reported that her income was zero and her husband’s
                income was zero. The former Executive Director had made
                an agreement with the Housing Authority where she would
                receive pay through August 15th. According to her
                husband’s new employer, he had started working three days
                prior to the Executive Director reporting zero income. This
                underreporting of income reduced their payment from $404
                per month to the minimum administrative fee of $110 per
                month. The payment should not have been reduced until
                the former Executive Director’s pay stopped, and the
                calculation should have included the husband’s income.
                This underreporting of income resulted in underpayment of
                approximately $1,400.

                One of the former Executive Director’s sister’s family income
                was understated

                Income used in the Housing Authority’s payment
                calculations was understated on two occasions. In October
                1995 the sister’s income was shown as zero while State
                income records for the period show that she earned income
                from two employers.3 The understated income lowered

2
  The Housing Authority did not have required releases in the file. Without the release
this employer would not provide information. Since we were unable to confirm specific
dates of employment, we made our calculations as if the individuals were employed for
the entire period, based on the State’s income information.
3
  The Housing Authority did not have required releases in the file. Without a release
these employers would not provide information. Since we were unable to confirm
specific dates of employment, we performed our calculations as if the individuals were
employed for the entire period using State income information.



                                                                                     14
                                                                     98-SE-207-1001


                monthly payments from $314 to $225 per month for 14
                months. The next calculation effective December 1996 was
                based on an annual income of $33,370. This amount was
                included on the Housing Authority’s payment calculation
                form and was taken from six month year to date income
                statements provided by the sister. The amounts on the
                calculation form were consistent with the information
                provided; however, the calculation was in error because the
                amounts were not annualized. This resulted in annual
                income used for the payment calculation being one half of
                the proper amount. This calculation was obviously
                incorrect; however, the sister signed the calculation as
                accurate. This resulted in a monthly payment of $200 rather
                than $400 for eight months, until August 1997. The
                understated income resulted in underpayments of
                approximately $4,050.

                Another of the former Executive Director’s sister’s family
                income was understated

                Income used in the Housing Authority’s payment
                calculations was understated several times. An October
                1994 payment calculation showed that the sister’s husband
                was the only source of income for the family. State income
                information shows that both the husband and wife earned
                income during the final quarter of 1994 and continued to
                earn income from the same employer during all four quarters
                of 1995.4

                The Housing Authority’s payment calculation in June 1995
                shows that the sister was not working and that the family
                annual income was $20,034. The calculated monthly
                payment was $142. However, State income information
                shows that the sister earned income during all four quarters
                of 1995 and the actual family income was $43,209 which
                would have required the family to make a monthly payment
                of $432.


4
  The Housing Authority did not have required income releases on file. Employers prior
to December 1995 were not willing to provide information without a release. Since we
were unable to confirm specific dates of employment, we assumed the individuals were
employed the entire period for purposes of our calculations. In addition, we used future
earnings for calculations because payment calculations are based on anticipated
earnings. Both the husband and wife worked at the same employer from December
1995 to present. This employer confirmed employment but would not provide
information on wages.



                                                                                      15
                                                  98-SE-207-1001



     In August 1996 a payment calculation took effect increasing
     the payment to the maximum of $455. In October 1996, the
     payment was recalculated using only the sister’s income in
     the calculation because her husband had moved out. There
     is no documentation in the file to indicate when the husband
     moved back into the home; however, in May 1997 the
     husband was apparently back because only his income was
     used in the calculation.

     According to a former employee responsible for income
     recertifications at the time, the husband moved back into the
     home about November 1996 and she tried to get information
     from the sister to do an updated payment calculation.
     According to the former employee, she could not get the
     necessary information, and the former Executive Director
     took no action to complete the payment calculation.

     According to their current employer, both the sister and her
     husband have been employed full time since December
     1995. In fact, according to State employment records the
     family income for 1996 was $48,830 and for 1997 would be
     projected at $46,235 based on first quarter earnings. Given
     these income amounts the family should have continued to
     make the maximum payment of $455 except for the time
     when the husband was not living in the home.

     On October 27, 1997 the husband came to the Housing
     Authority office and stated that his wife would be going on
     maternity leave and would therefore not be working and
     wanted to get his house payment adjusted. This could not
     be done because according to the prior information provided
     in May 1997 the wife was shown as not having any income.
     In addition, the sister’s employer informed us that the sister
     plans to go on maternity leave and will take advantage of a
     company benefit that will provide her 60 percent of her
     regular pay for up to three months.

     The projected underpayment from the understated income
     was approximately $6,500.

Subleases




                                                                16
                                                                    98-SE-207-1001


        The Housing Authority did not properly calculate the payments for
        two sublet homes resulting in an abuse5 of the Mutual Help
        program because one homebuyer profited from the sublease
        arrangements. In addition, the Housing Authority did not approve
        the subleases in writing.

                A cousin of the former Executive Director profited from
                subleasing her Mutual Help home

                A cousin of the former Executive Director has moved out of
                her Mutual Help home and sublet her home. According to
                the interim Executive Director, this person is currently living
                with her mother, also a Mutual Help homebuyer. Documents
                in the cousin’s Mutual Help file include a memorandum
                stating that the cousin had moved into her mother’s house
                and is subleasing her home for $200.00 per month.
                Documents do not state how long this arrangement has
                been in effect. Also, the homebuyer did not obtain prior
                approval or execute a written sublease agreement.

                Currently the cousin’s payment to the Housing Authority is
                calculated based on her family income and is set at $110
                per month. According to documents in the Mutual Help file
                the cousin is charging $200 per month on her sublease and
                is therefore receiving $90 per month more than the required
                monthly payment on her Mutual Help home. We were
                unable to calculate a total profit for the cousin because
                documents in the file do not indicate how long this sublease
                has been in effect, and our attempts to contact the cousin to
                get more detailed information were unsuccessful. There are
                no laws or regulations prohibiting Mutual Help participants
                from profiting on subleases. In our opinion profiting from
                subleases is an abuse of the Mutual Help program because
                taxpayers would not expect a low income home ownership
                program to provide the program participants the opportunity
                to earn rental income.

                Our review of the cousin’s and her mother’s payment
                calculations show that neither are done properly. The
                cousin’s payment calculation should include her income

5
 According to government auditing standards, abuse is distinct from illegal acts and
other noncompliance. When abuse occurs, no law, regulation, contract provision, or
grant agreement is violated. Rather, the conduct of a government program falls far short
of societal expectations for prudent behavior.




                                                                                    17
                                                                     98-SE-207-1001


                from the rent she is receiving on her sublease. While this
                understated her income, it would have no effect on her
                monthly payment because of the level of her other income.
                Since the cousin is reportedly living with her mother, the
                cousin’s family income including rent from the sublease,
                should be included in the mother’s payment calculation.
                Including the cousin’s family income, there would be an
                increase in the mother’s monthly payment by approximately
                $165 per month. We were unable to calculate the total
                underpayment because documents do not indicate how long
                this arrangement has been going on and our attempts to
                contact the cousin and her mother to get more information
                were unsuccessful.

                A friend6 of the former Executive Director sublet her Mutual
                Help home without approval and paid less than required for
                her home

                A friend of the former Executive Director signed a Mutual
                Help Occupancy Agreement in September 1995. The
                Mutual Help file includes two payment calculations based on
                the friend’s income that were effective December 1, 1995
                and June 1, 1996. These payment calculations required
                monthly payments by the friend of $547 and $222
                respectively. Housing Authority accounting records show
                that neither of these charges were input into their
                accounting system and therefore the friend was never
                required to make these payments. The highest monthly
                payment charged, according to Housing Authority
                accounting records, was $105 per month.

                Documents in the Mutual Help file shows that the friend was
                renting the home and the renter was making the monthly
                payments to the Housing Authority. Housing Authority files
                do not contain any written agreements approving this
                sublease.

                A hand written note in the file indicates that the renter
                moved out and the friend moved into the home in March
                1996. The friend moved out and terminated her contract in
                May 1997. At the time the friend moved out required repairs

6
 The relationship between this individual and the former Executive Director was
characterized by Housing Authority staff as friends. We were unable to locate the friend
and the former Executive Director would not comment on our results. Therefore, we
could not confirm the relationship.



                                                                                     18
                                                         98-SE-207-1001


             were estimated at $19,500. None of these repairs were
             charged to the account of the friend, and these repairs were
             made and paid for by the Housing Authority when converting
             the home to be handicap accessible. In addition, during the
             term of the Mutual Help contract the friend was
             undercharged for monthly payments by approximately
             $4,000 since December 1995.

Valid allegation regarding maintenance and vacancies of Mutual
Help homes

The complainant alleged that Mutual Help homes were not properly
maintained and homes sat vacant for extended periods of time.

What the criteria requires

Requirements for maintaining the physical condition and periodic
maintenance of Mutual Help homes during our audit period were included
in Federal Regulations at 24 CFR 905.345, 425, and 428 until they were
superseded by 24 CFR 950.345, 425, and 428. These regulations
require the following:

   The Housing Authority is responsible for adopting policies and
   procedures to assure full performance of the respective maintenance
   responsibilities of the Housing Authority and homebuyers. In
   summary, the homebuyer is responsible for all general maintenance of
   the home including replacement of major systems unless the system is
   under warranty.

   The Housing Authority is responsible for inspecting the homes to
   determine if maintenance of the home is satisfactory, and if not
   satisfactory then taking steps necessary to ensure that maintenance is
   performed.

Specific property standards are not mentioned in the Mutual Help
regulations except to state that homes are to be maintained in a decent,
safe, and sanitary condition. Housing Authority policies did not adopt
specific property standards for maintenance. During our review we
performed our inspections using Section 8 Housing Quality Standards.
After completing our inspections we reached agreement on items we
identified as health and safety violations with the Housing Authority
Maintenance official.

What we concluded




                                                                       19
                                                          98-SE-207-1001


Housing Authority staff had not enforced Mutual Help occupancy
agreements and had not required homebuyers to maintain their homes in
decent, safe, and sanitary condition. Also, Board members did not take
an active oversight role to determine why occupied homes were not
properly maintained and vacant homes were not repaired and occupied,
and ensure that the problems were corrected. In addition, the Board did
not ensure that Housing Authority policies met regulatory requirements
and included maintenance standards.

During August and September 1997 we inspected a total of 17 Mutual
Help homes, 10 occupied and 7 vacant, to determine if the homes were
maintained in decent, safe, and sanitary condition as required by the
Mutual Help program. The Board did not comply with the regulatory
requirement that the Housing Authority adopt maintenance standards for
their Mutual Help homes. Due to the lack of adopted standards we used
Section 8 Housing Quality Standards as the basis for our inspections. In
addition, after our inspections we presented our results to the Housing
Authority Maintenance official responsible for inspections to determine if
there were any areas of disagreement on what we classified as health
and safety hazards. There were no disagreements on our results.

Of the homes inspected, seven occupied homes and four vacant homes
had health and/or safety hazards. At the time of our review, vacancy
periods for the homes ranged from 3 months to 13 months. Further
review of the Mutual Help files for these homes showed that for eight of
the homes where we identified health and/or safety hazards, the hazards
had been identified by the Housing Authority in previous annual
inspections but were not corrected. The following table shows the homes
inspected and the number of health and safety violations identified.

      Address                  Health and/or Safety Violations
OCCUPIED UNITS
2369 Sidwigwilxe                               9
2311 Choba Ahbsh                               6
5332 Chief Brown Lane                          5
2359 Sabolic                                   4
2329 Sidwigwilxe                               4
708 Nookwa Chahbsh                             2
732 Nookwa Chahbsh                             2
5338 Chief Brown Lane                          0
5308 Chief Brown Lane                          0
2331 Sidwigwilxe                               0

VACANT UNITS



                                                                        20
                                                       98-SE-207-1001


742 Nookwa Chahbsh                          18
5310 Chief Brown Lane                       12
5332 Chief Brown Lane                        6
5312 Chief Brown Lane                        3
720 Nookwa Chahbsh                           0
2309 Choba Ahbsh                             0
2353 Sbalikwh                                0


The health and safety violations in occupied homes included:


Raw sewage in
the crawl space
of the home at
2311 Choba
Ahbsh. This
violation was
discussed at the
January 1996
Board meeting
but was not
properly
repaired.




A hole in laundry
room floor of the
home at 2329
Sidwigwilxe. This
violation was
discussed at the
July 1996 Board
meeting and
identified in the
1996 annual
inspection but was
never repaired.




                                                                  21
                  98-SE-207-1001




Rotten kitchen
cabinets in the
home at 2369
Sbalikwa.




                             22
                                                        98-SE-207-1001




The health and safety violations in the vacant homes included:




A hole in the bathroom
floor of the home at
5310 Chief Brown Lane.
This violation was
identified in an annual
inspection while the
home was still
occupied.




A rotten floor in the
bathroom of the home
at 5312 Chief Brown
Lane. This violation is
causing the toilet to
lean.




Also, there is no indication of any definitive effort by the Board to
determine why the homes, both occupied and vacant, were not properly
maintained and occupied. For example, at least two of the health and
safety violations above were discussed at Board meetings but were not
repaired or not repaired properly.



                                                                    23
                                                            98-SE-207-1001


C. CONCLUSION

Favored treatment of relatives, underreported and understated
income, underpayments, and poor maintenance of homes impact
individuals and the organization as a whole

The issues we identified in our audit impact not only the individuals
involved but the organization as a whole. By awarding a Section 8
Voucher and a Mutual Help home to ineligible family members, the Board
and former Executive Director not only provided an inappropriate benefit
to their family, but also denied housing to eligible low income Tribal
members. By underreporting and understating income, the former
Executive Director and her family members received an inappropriate
financial benefit because their monthly payments were lower than
required. In addition, equity accounts for the homes are underfunded.
These equity accounts serve as security for the homebuyer and the
Housing Authority because they can be used to make repairs to the
home. By not enforcing maintenance requirements for occupied homes,
and not repairing and occupying vacant homes in a timely manner,
families are living in unsafe and unhealthy conditions and in some
instances for extended periods of time. In addition, other low income
families are denied housing because vacant homes sit and deteriorate.

Why the deficiencies occurred

As the audit results above demonstrate, the Board, which included the
former Executive Directors father, did not adequately carry out their
oversight responsibilities over the Housing Authority, and in our opinion
this lack of oversight contributed to the deficiencies we identified in our
audit.

According to two former Board members, the former Executive Director
was hired by the Board even though they knew she was not qualified for
the position. The Board members stated that the former Executive
Director did not have any experience in this type of position but she was a
Tribal member and was the only applicant with any experience in HUD
programs. These Board members statements that the Executive Director
was not qualified for the position are consistent with statements from HUD
staff. According to the HUD representative responsible for the Housing
Authority she was aware of the former Executive Director prior to her
hiring, and knew that her experience did not prepare her for the Executive
Director’s position. The HUD representative stated that the Executive
Director was completely overwhelmed with the position.




                                                                          24
                                                          98-SE-207-1001


In addition, the Board did not take the necessary steps to ensure that
Housing Authority policies complied with the regulatory requirements for
the Mutual Help program. Housing Authority policies do not include a
policy on subleases and also do not adopt maintenance requirements.

Also, there is no indication of any definitive effort by the Board to
determine why the homes, both occupied and vacant, were not properly
maintained.

Evidence accumulated during our audit also demonstrates that the former
Executive Director took advantage of her position to provide favored
treatment to herself, her family members, and a friend. In addition, the
former Executive Director did not ensure that income recertifications and
payment calculations were accurate, Mutual Help homes were properly
maintained, and vacant Mutual Help homes were repaired and awarded to
eligible homebuyers.


D. ACTIONS TAKEN BY THE TRIBES
In July 1997, based on information brought to the attention of the Upper
Skagit Tribe’s General Manager and Controller by Housing Authority staff,
the former Executive Director identified in the deficiencies in this report
was relieved of her position at the Housing Authority.

In addition, after the former Executive Director was relieved of her
position, the members of the Board were removed by the Tribes and an
Interim Board was put in place made up of members of the Tribal
Councils.

The Upper Skagit and Sauk Suiattle Tribes are currently in the process of
separating their housing operations due to the new Native American
Housing and Self Determination Act. This will result in the dissolution of
the Housing Authority as it currently exists.

These actions by the Tribes were taken into consideration when
developing the recommendations for this report.


E. AUDITEE COMMENTS AND OIG EVALUATION
Auditee Comments




                                                                        25
                                                           98-SE-207-1001


On December 5, 1997 we provided a draft of this report to the Interim
Board for their comments. They provided written comments to the draft
report in a letter dated December 12, 1997.

The Housing Authority generally agreed with the results of our audit.
However, the Housing Authority commented that without additional time to
review all the files and obtain additional information on employment and
income, they could not corroborate the specific amounts in our draft
report. In addition, the Housing Authority stated that the individual
identified in our draft report as a former sister-in-law was not actually a
relative of the former Executive Director. The Housing Authority also took
exception to recommendation F in our draft report. They see this
recommendation as giving sole responsibility for determining the Tribes’
capability for future administration of housing programs to a federal
agency that failed in its performance of its oversight responsibility. A
complete copy of the Housing Authority’s comments is included in
Appendix 1.

OIG Evaluation

We discussed and agreed on the timeframe for comment on the draft
report with the Housing Authority prior to providing the draft report for
comment. This agreement was reached recognizing that the amount of
time for comment on this draft report was not sufficient for the Housing
Authority to review files and obtain information necessary to verify all
amounts and calculations in our audit report. In addition, we state in this
report that we were unable to determine certain dates of employment and
wages. For these reasons our report recommends that the Housing
Authority obtain information necessary to determine specific dates of
employment and wages prior to making any decisions on the cases cited.

Due to the conflicting information obtained from the Board and staff on the
relationship of the individual that we identified as a former sister-in-law,
we contacted the Housing Authority staff again to determine if they had
any documentation of the relationship. They did not, but stated that their
observation of the relationship over the years demonstrated that they
were good friends. Because of the conflicting information we changed the
report to refer to this person as a friend of the former Executive Director.
We did attempt to contact the friend during our audit but could not locate
her. As discussed in our audit scope, the former Executive Director would
not comment on our audit results or answer any questions.

We acknowledge that HUD does have oversight responsibility for the
Housing Authority. However, it was not in the scope of our audit to
determine whether or not HUD failed in any of its oversight



                                                                         26
                                                           98-SE-207-1001


responsibilities, and therefore, we have no comment at this time on the
auditee position. Our recommendation is based on the fact that under
NAHASDA, HUD continues to have oversight responsibility, and given the
performance history documented in this report we believe it is prudent for
HUD, as the oversight entity, to evaluate the administrative capability of
the entity designated by the tribes prior to awarding any funds.
Therefore, we made no change to our recommendation.

F. RECOMMENDATIONS
We recommend that HUD:

A. Require the Housing Authority to obtain the information necessary
   and calculate the amount of underpayment of Mutual Help payments
   where income was underreported or understated and make
   retroactive charges to the homebuyers.

B. Require the Housing Authority to evaluate the sublease situations in
   accordance with terms of the Mutual Help Occupancy Agreements,
   and either reach agreements for approved subleases that do not
   abuse the program, or terminate the current Mutual Help agreements
   and award the homes to new, eligible homebuyers.

C. Determine what action, including Debarment or Limited Denial of
   Participation, is appropriate for the former Executive Director, and the
   families with underreported or understated income.

D. Require the Housing Authority to immediately take all necessary
   action, including termination and eviction if appropriate, to repair the
   homes and enforce maintenance provisions of their Mutual Help
   Occupancy Agreements.

E. Require the Housing Authority to determine the eligibility of the sister
   and her family who were awarded the Section 8 Voucher, and if
   determined ineligible, reimburse the Section 8 program from non-
   federal funds, for all payments made on the Section 8 Voucher.

F. Perform an evaluation to determine if these Tribes or their Tribally
   Designated Housing Entities have the necessary administrative
   capability to be recipients under the Native American Housing and
   Self Determination Act.




                                                                          27
                                                           98-SE-207-1001



Internal Controls
In planning and performing our audit, we considered the Housing
Authority’s management controls relating specifically to our objectives, to
determine our auditing procedures and not to provide assurance on
management controls.

Management control is the process by which an entity obtains reasonable
assurance as to achievement of specified objectives. Management
controls consist of interrelated components, including integrity, ethical
values, competence, and the control environment which includes
establishing objectives, risk assessment, information systems, control
procedures, communication, managing change, and monitoring.

We determined that the management control categories relevant to our
audit objectives were the Housing Authority’s policies, procedures, and
practices for ensuring that:

•   Construction services were procured in accordance with all applicable
    requirements.
•   Comprehensive Improvement Assistance Grant funds were used for
    eligible purposes.
•   Travel by Housing Authority staff was done in accordance with
    applicable policies and procedures.
•   Only eligible applicants receive Section 8 Vouchers and the amount of
    assistance provided on Section 8 Vouchers is appropriate.
•   Only eligible applicants receive Mutual Help homes and that Mutual
    Help participants pay the proper amount for their homes.
•   Mutual Help homes, both occupied and vacant, are maintained in
    accordance with applicable standards.

We evaluated the relevant controls as necessary to determine
appropriate audit procedures for evaluating the allegations in the
complaint. Because of the limitations on the scope of our audit, we did
not gain a thorough understanding of all management controls, and did
not rely on management controls in our audit work.




                                                                          28
                   98-SE-207-1001



Appendices
Appendix 1
Auditee Comments




                              29
98-SE-207-1001




           30
98-SE-207-1001




           31
98-SE-207-1001




           32
98-SE-207-1001




           33
98-SE-207-1001




           34
98-SE-207-1001




           35
98-SE-207-1001




           36
98-SE-207-1001




           37
98-SE-207-1001




           38
                                                        98-SE-207-1001


Appendix 2

Distribution
Secretary’s Representative, 0S (2)
Office of the Comptroller, 9AFF
Acting Administrator, NW Office of Native American Programs, NONAP (2)
Director, Administrative Service Center, 8AFF
Director, Field Accounting Division, 0AAF
Deputy Secretary, SD, Rm. 10100
Assistant Secretary for Public & Indian Housing, P, Rm. 4100
Assistant Secretary for Congressional & Intergovernmental Relations, J, Rm.
10120
Deputy Assistant Secretary for Public Affairs, W, Rm. 10130
Chief of Staff, S, Rm.10000
Counselor to the Secretary, S., Rm. 10000
Senior Advisor to the Secretary for Communication Policy, S, Rm. 10000
Acting General Counsel, C, Rm. 10214
Assistant to the Deputy Secretary for Field Management, SDF, Rm. 7106
Audit Liaison Officer, PF, Rm. 5156 (3)
Acquisitions Librarian, Library, AS, Rm. 8141
Chief Financial Officer, F., Rm. 10164 (2)
Deputy Chief Financial Officer for Finance, F, Rm. 10166 (2)
Deputy Assistant Secretary, Native American Programs, PI (Denver)
Director, Office of Press Relations, WR, Rm. 10138
Assistant to the Secretary for Labor Relations (Acting), SL, Rm. 7118

Director, Housing & Community Dev. Issue Area
US GAO
441 G. Street NW, Rm. 2474
Washington, DC 20548
Attn: Judy England-Joseph

Honorable Pete Sessions
Government Reform and Oversight Committee
Congress of the United States
House of Representatives
Washington, DC 20515-4305

Honorable Fred Thompson, Chairman
Committee on Governmental Affairs
United States Senate
Washington, DC 20510-6250



                                                                     39
                                                     98-SE-207-1001


Honorable John Glenn, Ranking Member
Committee on Governmental Affairs
United States Senate
Washington, DC 20510-6250

Honorable Dan Burton, Chairman
Committee on Government Reform and Oversight
House of Representatives
Washington, DC 20515-6143

Ms. Cindy Sprunger
Subcommittee on General Oversight & Investigations
O’Neill House Office Building, Rm. 212
Washington, DC 20515

Honorable Jack Metcalf
Attn: Roy Atwood
2930 Wetmore Avenue, #901
Everett, WA 98201

Cascade Inter-Tribal Housing Authority
2284 Community Plaza
Sedro Woolley, WA 98284




                                                                40
                                                     98-SE-207-1001



OIG

Susan Gaffney, Inspector General, G, Rm. 8256
J. Connors, Deputy Inspector General, G, Rm. 8256
Michael G. Zerega, Public Affairs Officer, G, Rm. 8256
Counsel to the IG, GC, Rm. 8260
K. Kuhl-Inclan, AIG Audit, GA, Rm. 8286
M. Phelps, DAIG Audit, GA, Rm. 8286
Director, Program Research & Planning Division, GAP, Rm. 8180
Director, Financial Audits Division, GAF, Rm. 8286
Central Records, GF, Rm. 8266 (4)
Semi-Annual Report Coordinator, GF, Rm. 8254
SAC, Office of Investigations, 0AGI
AIG, Office of Investigations, GI, Rm. 8274
Deputy AIG, Office of Investigation, GI, Rm. 8274




                                                                41