oversight

San Francisco HA Drug Elimination Program, San Francisco, CA

Published by the Department of Housing and Urban Development, Office of Inspector General on 1998-07-22.

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

                           Audit Report
                           District Inspector General for Audit
                           Pacific/Hawaii District
                           Report: 98-SF-201-1003                      Issued: July 22, 1998



TO:           Joyce L. Lee, Director, Office of Public Housing, 9APH


FROM:         Glenn S. Warner, District Inspector General for Audit, 9AGA

SUBJECT:      San Francisco Housing Authority
              Drug Elimination Program
              San Francisco, California


As part of the Inspector General’s nationwide review of HUD’s drug elimination program, we
conducted an audit of that program at the San Francisco Housing Authority.

The report’s six findings discuss excessive and unsupported costs; poor procurement prac-
tices; inadequate program monitoring, evaluation and reporting; and changes to implementa-
tion plans prior to HUD approval. Within 60 days, please furnish us a status report on the
corrective action taken, the proposed corrective action and the date to be completed, or why
action is not considered necessary for each recommendation in the report. Also, please fur-
nish us with copies of any correspondence issued because of the audit.

If you or your staff have any questions, please contact senior auditor Mark Pierce at 436-
8101.
                                                                     98-SF-201-1003




Executive Summary
This audit of the drug elimination program at the San Francisco Housing Authority
covered activities of the 1994, 1995, and 1996 grant awards through December
31, 1997. The objective was to review how the housing authority managed its
drug elimination grants to obtain expected outcomes, and determine if grant funds
were used in conformance with requirements. We concluded that the housing
authority needs to improve management practices and evaluation methods to as-
sure the program is properly implemented and the intended goals are accom-
plished. The housing authority should also return certain funds. Conditions need-
ing correction are discussed in six findings.

                       The San Francisco Housing Authority overpaid the San
Police Overpaid
                       Francisco Police Department up to $372,504 for police
services from January 15, 1996 through June 13, 1997 under two separate con-
tracts. These funds came from the drug elimination program grants and a HUD
comprehensive rehabilitation grant. The police billed at hourly rates and for hours
exceeding the level specified in the contracts, thus reducing amounts available for
additional eligible activities. This occurred principally because police and housing
authority officials responsible for preparing invoices and approving payments were
not sufficiently familiar with the terms of the contracts. (See page 4.)

                                                      The program was charged
Improper and Unsupported Payroll Charges
                                                      $28,951 for two employees
performing jobs unrelated to drug elimination activities, and $56,272 for the for-
mer director of neighborhood initiatives when he was providing no services. Also,
the housing authority did not require employees to document time spent on grant-
related activities. Consequently, the accounting records did not show that
$407,940 charged to the program was proper. The ineligible and unsupported
charges occurred because department heads were not provided with payroll data
for their review, and payroll was charged based on predetermined percentages.
Excessive charges for payroll expenses reduce the amount of funds available for
drug elimination activities. (See page 10.)

                                                 Under three contracts with differ-
Unsupported Payments to Contractors
                                                 ent community-based entities, the
housing authority paid out $20,500 for unsupported “start-up costs.” In addition,
the housing authority paid out the balance of $22,500 remaining under the contract
with the third entity even though performance under the contract had hardly
started. As a result, at the time of payment there was no assurance that the funds
were used in accordance with federal requirements. This occurred because of poor




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procurement procedures and as an expedient to use grant funds before the 1994
drug elimination grant expired. (See page 15.)

                                     Procurement practices for the drug elimination
Poor Procurement Practices
                                     program were inadequate. Documentation of
the procurement process was generally unavailable. Evidence was lacking that
adequate cost analyses were performed prior to entering into contracts. The hous-
ing authority sometimes improperly inserted fixed-price portions into contracts that
should have been entirely cost-reimbursable. Sometimes written contracts were
absent. This was due to decentralization of procurement operations making it dif-
ficult to control and monitor contracting activities. These weaknesses resulted in
excessive and unsupported costs and potentially could lead to disputes with con-
tractors as well as give the appearance of possible favoritism. (See page 18.)

                                                        The housing authority had
Ineffective Program Monitoring & Evaluation
                                                        not established a process
to measure program effectiveness and to help assure the accomplishment of the
program’s objectives and goals. It had not established a systematic method of data
collection and analysis to measure success in achieving goals. It had not
adequately monitored its contractors. Consequently, the housing authority could
not submit to HUD progress reports with sufficient information on program
results. These conditions occurred because management lacked sufficient
appreciation or awareness of sound monitoring and evaluation practices. While
limited anecdotal evidence indicated a decrease in drug-related crime, overall
conclusions could not be drawn. (See page 23.)

                                             The housing authority made substan-
Program Changes Not Preapproved
                                             tial changes to its 1994, 1995, and
1996 drug elimination programs. However, it did not seek or obtain HUD ap-
proval as required prior to implementing the changes. This occurred because offi-
cials did not appreciate the need to obtain HUD’s advance approval. As a result,
HUD was not given the opportunity to evaluate the revised plans before they were
put into effect. Also, the housing authority put itself in possible fiscal jeopardy if
HUD disapproved the changes. (See page 30.)

Our conclusions consider comments from the housing authority, including written
remarks displayed in appendix 2 (starting on page 35), and a conference held on
July 17, 1998 with the executive director and other housing authority officials.
The housing authority generally concurred with the audit’s conclusions.




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Contents
Management Memorandum................................................................................... i

Executive Summary ............................................................................................. ii

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

Findings

          1. The housing authority overpaid the police for contracted services ....... 4

          2. Ineligible and unsupported payroll expenses were charged................. 10

          3. Payments to three entities were not supported................................... 15

          4. Procurement practices need improvement ......................................... 18

          5. The housing authority did not adequately monitor or evaluate its
             program............................................................................................ 23

          6. Approval for program changes was requested after the fact............... 30

Management Control.......................................................................................... 33

Appendices

          1. Schedule of Ineligible & Unsupported Amounts and Efficiencies ....... 34

          2. Auditee Comments ........................................................................... 35

          3. Distribution....................................................................................... 47




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Abbreviations
CFR     Code of Federal Regulations (a codification of federal require-
        ments)

DEP     Drug Elimination Program (federal grant program for eliminating
        drug-rekated crime in public housing)

GASA    Girl’s After School Academy (a community-based entity that re-
        ceived DEP funds)

HUD     U.S. Department of Housing and Urban Development (grantor for
        the drug elimination program)

NOFA    Notice of Funding Availability (provides procedures for applying
        for grants and identifies program requirements)

OCRI    Office of Community Relations and Involvement (a division of
        SFHA)

OIG     Office of Inspector General, U.S. Department of Housing and Ur-
        ban Development (performed the subject audit)

OMB     Office of Management and Budget (an executive agency that es-
        tablishes certain federal policies)

SFES    San Francisco Educational Services Academy (a community-based
        entity that received DEP funds)

SFHA    Housing Authority of the City and County of San Francisco, com-
        monly known as the San Francisco Housing Authority (recipient of
        drug elimination grants and the subject of this audit)

SFPD    San Francisco Police Department (provided supplemental police
        services funded by SFHA’s DEP)

TURF    Together United Recommitted Forever (an on-site patrol/interven-
        tion program funded by SFHA’s DEP)




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Introduction
BACKGROUND

                  Under the drug elimination program, HUD provides grants for
The Program
                  the purpose of addressing drug-related crime and its associated
problems in and around public housing developments. The San Francisco Housing
Authority has received such grants from 1991 through 1996. It applied for a
$1,554,540 grant in 1997 but was turned down.

              Year       Award          Expended        Remaining
                         Amount           (as of         Balance
                                         1/1/98)
               91        $1,012,898      $1,012,898               $0
               92         1,013,550        1,013,550               0
               93           973,550          973,536               0
               94         1,681,750        1,681,750               0
               95         1,669,250        1,484,856         184,394
               96         1,689,250          102,647       1,586,603
              Totals     $8,040,248      $6,269,237       $1,770,997

                            The San Francisco board of supervisors established
The Housing Authority
                            the Housing Authority of the City and County of San
Francisco -- commonly known as the San Francisco Housing Authority -- in 1938.
The city mayor appoints the members of the housing authority’s governing body, a
board of commissioners.

In 1940 the housing authority opened the city’s first low-income housing devel-
opment for 118 families. The housing authority has grown to include 43 develop-
ments with a total of nearly 6,000 housing units. Also, since the 1974 inception of
the Section 8 program, the number of low-income families whose rents are subsi-
dized for privately owned housing has risen to approximately 5,500.

For its fiscal year ended in 1997, the San Francisco Housing Authority expended
$128 million. As graphically presented on the following page, its largest programs
consisted of Section 8 ($51 million), low-income housing operations ($33 million),
modernization ($24 million), HOPE VI new development ($16 million), and drug
elimination ($2.8 million).




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                                              drug
                           HOPE VI         elimination
                         development           2%
                            13%

             modernization                                       section 8
                19%                                                39%




                             low-income                  other
                              operations                  1%
                                26%


                                   The housing authority had been much criticized
HUD’s Temporary Control
                                   for its perceived lack of competent leadership,
of the Housing Authority           physical decay of its housing, poor performance
in collecting rent, and the high level of crime existing at its housing developments.
As a result, in March 1996 the city’s newly-elected mayor, Willie Brown, an-
nounced the firing of the housing authority’s commissioners and executive direc-
tor. The mayor invited HUD to run, temporarily, the housing authority and reor-
ganize it, recruit new management, and establish new policies and procedures.

As a result, HUD sent a recovery team (consisting of HUD officials, consultants,
and employees from other housing agencies) in March 1996 to assess the housing
authority’s operations and develop strategies to deal with the problems. This
phase was concluded in November 1996 by which time most of the initial team
members had left. HUD filled several key management positions by contract to
continue the recovery efforts.

As part of the recovery effort, the acting HUD assistant secretary for public and
Indian housing functioned as the board of commissioners. In July 1997 the city
mayor installed a new board of commissioners, and HUD turned over control of
the housing authority to the board in September 1997. Ronnie Davis has been the
housing authority’s executive director since November 1996.

                   As part of a HUD Office of Inspector General (OIG) review of
The OIG Audit
                   the drug elimination program, the subject audit is one of sev-
eral covering different housing authorities’ drug elimination programs. While
OIG’s San Francisco office performed the audit of the San Francisco Housing
Authority, OIG’s Boston, Massachusetts office is doing the overall review of the
program.

AUDIT OBJECTIVE AND SCOPE

                                The objective of the audit was to review how the hous-
Purpose and Extent
                                ing authority managed its drug elimination grants to ob-


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tain expected outcomes, and determine if grant funds were spent in conformance
with requirements.

The audit examined activities of the three drug elimination grants1 awarded from
1994 through 1996 through December 31, 1997. The primary methodologies for
this work included:

            ü Consideration of the housing authority’s management control
              structure and assessment of risk as described on page 33.

            ü Tests of selected financial activities and transactions.

            ü Analysis of the housing authority’s grant applications and reports to
              HUD on the program’s activities.

            ü Review of the city police department’s records used to prepare
              billings submitted to the housing authority.

            ü Interviews of selected housing authority, city police and HUD offi-
              cials, and housing authority residents.

This report reflects consideration of auditee comments.

                We conducted the review in accordance with generally accepted
Standards
                government auditing standards.




1
  The 1994 grant was effective January 31, 1995 and expired July 30, 1997; the 1995 grant was
effective October 4, 1995 and expired March 17, 1998; and the 1996 grant was effective Decem-
ber 10, 1996 and expires November 27, 1998.



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Findings
Finding 1
The Housing Authority Overpaid the Police for
Contracted Services.
The San Francisco Housing Authority (SFHA) overpaid the San Francisco
Police Department up to $372,504 for police services from January 15, 1996
through June 13, 1997 under two separate contracts. These funds came from
the drug elimination program (DEP) grants and a HUD comprehensive re-
habilitation grant. The police billed at excessive hourly rates and for hours
exceeding the level specified in the contracts, thus reducing amounts avail-
able for additional eligible activities. This occurred principally because po-
lice and housing authority officials responsible for preparing invoices and
approving payments were not sufficiently familiar with the terms of the con-
tracts.


Payments to local law enforcement agencies for additional security and protective
services that are over and above baseline services are allowable expenses under the
drug elimination program. However, grant funds must be used only for allowable
costs that are reasonable and necessary as prescribed by OMB Circular A-87, Cost
Principles for State, Local and Indian Tribal Governments. Therefore, any pay-
ments in excess of that required under the terms of contracts for such services
would be unnecessary, and thus, unallowable.

This finding involves two intergovernmental agreements (contracts) between the
housing authority and the city police.

   ⇒ The housing task force contract was entered into on August 21, 1996 for
     a term of one year. The contract called for the police to provide 14 offi-
     cers full-time to perform supplemental police patrols within and in the vi-
     cinity of the housing developments. The $1,140,000 contract required the
     housing authority to reimburse the police for the officers’ actual compen-
     sation plus benefits, and the police were to supervise the officers at no ad-
     ditional cost. Of the total $1,111,542 paid on the contract, $800,000 was
     funded by the 1995 drug elimination grant, $189,577 by the 1994 drug
     elimination grant, and $121,965 by the 1996 comprehensive grant.




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   ⇒ The resource center contract was entered into on February 7, 1996 for a
     term of six months. The police were to provide community policing serv-
     ices at three resource centers. The $800,000 contract called for one Q-50
     sergeant at the fixed rate of $42.43 per hour and six Q-2 officers at the
     fixed rate of $36.5625 per hour to patrol the target sites a minimum of
     eight hours per day, five days per week. The 1994 drug elimination grant
     paid for all billings under this contract.

                                       The housing authority overpaid the police up
Housing Task Force Contract            to $366,988 on the housing task force con-
tract from August 24, 1996 through June 13, 1997. The housing authority fully-
paid invoices submitted by the police that included:

   •   hourly billing rates exceeding actual compensation and benefit costs of po-
       lice officers,

   •   hours spent in excess of the level of effort contracted for, consisting princi-
       pally of the time of supervisors which was to have been provided without
       charge, but also overtime hours unrelated to the subject contract.

                                The police billed a total of $1,111,542 (all but
Hours Billed at Higher          $28,458 of the total contract amount) for 29,561.5
Rates Than Specified            hours worked during the 21 pay periods from
August 24, 1996 through June 13, 1997 at the rates of $37.2900 an hour through
December 1996 and $37.8563 an hour from January 1997. The housing authority
paid the amounts as invoiced. These rates were the overtime rates for officers in
effect at the time, which were greater than the actual cost of compensation and
benefits for officers as provided for in the contract.

According to the City and County of San Francisco, which maintains cost and
hourly wage data for city workers, the cost of a police officer for compensation
plus benefits was $28.7808 per hour through December 1996 and $29.1644 per
hour from January 1997 for regular time. Thus, the housing authority overpaid an
average of $8.61 per hour billed (not considering a night differential of approxi-
mately $1.56 per hour).

                                         The contract called for the services of 14
Excess Level of Effort Charged
                                         full-time officers. Full-time officers work
80 hours each pay period (every two weeks). Thus, fourteen full-time officers
equals 1120 hours per pay period, or 23,520 hours for 21 pay periods. However,
the police charged 29,561.5 hours for 21 pay periods. That level of effort equals
17.6 full-time officers through June 13, 1997.

Most of this excess was due to billing the time of police supervisors (billed at offi-
cer overtime rates), which was to have been provided without charge. The director



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of HUD’s Office of Crime Prevention and Security, who helped negotiate the con-
tract, stated, “The contract disallowed the billing for supervisory hours, whether
performed in the office or on the beat.” It is generally accepted that sergeants,
lieutenants, and higher ranks are supervisors.

The police also included in billings overtime hours of various descriptions. While
some of the overtime hours may have been related to public housing, some were
clearly unrelated. For instance, during the period February through June 1997, the
police billed the housing authority for about 400 hours, duplicating what was also
billed directly to HUD for Operation Safe Home activities

                                                    The police stopped billing the
Police Recalculation of Contract Billings
                                                    housing authority after the July
25, 1997 invoice (covering services through June 13) when we brought these is-
sues to their attention. The police subsequently recalculated what they thought the
billings should be. The recalculation was based on actual compensation costs for
14 full-time officers (with no time of supervisors). It also included 1,984 hours of
“court” and “regular” overtime. The recalculation covering the entire period of the
contract (through August 20, 1997) showed total costs of $946,680, $164,862 less
than the amounts previously billed and paid of $1,111,542.

We reviewed the recalculation and took no material exception with it except for
the billing of certain overtime hours. We accepted 1,111 “court” overtime hours
since this work would be the result of the contracted level of effort. We inter-
preted the contract terms to call for the presence of 14 full-time officers for each
pay period. Since arrests made during such time would require court appearances,
it appears appropriate that such time be compensated by the housing authority.

An unquantified portion of the 873 “regular” overtime totaling $33,038, however,
was for such activities as investigations and undercover operations. Such activities
would appear to be those covered by the 14-officer level of effort called for in the
contract and would be effort in excess of the quantity of services contracted for.
Nevertheless, an unquantified portion also included overtime resulting from ar-
rests. We would consider this overtime reimbursable for the same reason given for
the “court” overtime.

Thus, subject to the resolution of “regular” overtime, we consider allowable costs
under the task force contract to be $744,554 through June 13, 1997, $366,988 less
than that billed; and $913,642 through August 20, 1997, $197,900 less than billed.

                                   The police billed the housing authority $404,615
Resource Center Contract           for service performed at the three resource cen-
ters from January 15, 1996 through June 14, 1996. The first two invoices billed
hours at the contract rates. Three subsequent invoices billed for night hours at a
higher rate than the hourly rates specified in the contract. A total of 766 sergeant



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night hours were billed at $44.20 (compared to the contract rate of $42.43) and a
total of 2,742 officer night hours were billed at $38.08 (compared to the contract
rate of $36.5625), causing an overbilling of $5,516. The housing authority paid
the amounts as invoiced.

            We believe the excessive billings occurred because the police officials
Causes
            responsible for the billings were not sufficiently familiar with the terms
of the contracts. For example, the police used billing rates (often overtime rates)
that were commonly used under similar contracts with the SFHA and others in-
stead of those specified in the two contracts. Prior to July 1996, overtime rates
approximated the hourly rate needed to cover an officer’s regular compensation
plus benefits, which may be why overtime rates were commonly used in past con-
tracts. However, SFPD’s retirement fund became fully funded in July 1996, caus-
ing the actual cost of officers to drop since payments to the fund were suspended.

Also, the police had not established sufficient procedures for identifying time spent
by task force officials on non-contract activities and for making the appropriate
billing adjustments. Generally, the task force submitted all hours worked by its
officers to the SFPD fiscal department which prepared the invoices to the housing
authority. The task force’s intent was to point out to the housing authority that
more hours were worked than were billed. However, the task force did not pro-
vide a breakdown of hours to the police fiscal department to indicate which hours
were to be billed or not billed. Therefore, the fiscal department used the totals to
formulate the invoices. In so doing, the Operation Safe Home and other noncon-
tract-related hours were included in the bills to the housing authority.

Similarly, housing authority officials were also not sufficiently familiar with the
contract terms. Although department heads responsible for administration of the
contracts reviewed the billings prior to payment, their review was generally limited
to checking mathematical accuracy. Billing rates and composition of services
billed (supervisory versus non-supervisory) were not compared to those specified
in the contracts, and the reviewing officials were not aware of the bases for the
rates used.

The housing authority’s inadequate review of the billings may be due to its lack of
written procedures or other instructions for directors and other contract monitors
to follow when reviewing contract-related invoices for payment.

AUDITEE COMMENTS & OIG EVALUATION

The SFHA concurred with this finding and indicated it had implemented or was in
the process of implementing the following actions.




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       •   Gained SFPD agreement to offset the total amount of overpayments,
           $203,415, against current and future SFPD billings. The accounting
           records and reports to HUD would be revised to reflect this.

       •   Obtained SFPD agreement to provide more detailed invoices to permit
           effective reviews.

       •   Developed written procedures for processing invoices including a re-
           view checklist. The SFHA was in the process of training staff and im-
           plementing the new procedures.

The SFHA was generally responsive to the audit recommendations. SFHA’s new
checklist should help assure that payments conform to contract terms. Still, a revi-
sion should be made to assure that billing rates, when applicable, match rates
specified in the contracts. The current checklist requires that billed rates match
contract rates only when they are indicated on the invoice. The reviewing official
should always determine whether the billing rates agree with contract terms, and if
the rates are not shown on the invoice, a revised invoice should be obtained.
SFHA officials said they would revise the checklist.

RECOMMENDATIONS

We recommend that you require the housing authority to:

   A. Reimburse the program for the excessive payments to the police, including
      (1) $164,862 ($121,965 to the comprehensive grant and the remainder to
      the 1995 DEP grant) under the task force contract, plus all or part of
      $33,038 of “regular” overtime as you deem appropriate (to the 1995 DEP
      grant), and (2) $5,516 (to the 1994 DEP grant) under the resource center
      contract. If you want to consider SFHA’s proposal to reimburse the pro-
      gram by offsetting police billings under subsequent contracts, you should
      determine whether reprogramming of federal funds is necessary and appro-
      priate.

   B. Require the police to establish sufficient procedures for identifying time
      spent by task force officers on contract activities and assuring that correct
      billing rates are used.

   C. Adjust its accounting records and submit revised financial reports to HUD
      to eliminate the effects of the over payments.

   D. Provide proper training and written instructions for its officials to assure
      contract payments are correct and proper. The training and instructions
      should include billing review procedures as well as for the monitoring of



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contractors to assure that their billing procedures are sufficient and that
contractor officials are aware of the terms and conditions of the contracts.




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Finding 2
Ineligible and Unsupported Payroll Expenses Were
Charged.
The SFHA charged $28,951 to the DEP for two employees performing jobs
unrelated to DEP activities, and $56,272 for the former director of neighbor-
hood initiatives when he was providing no services. Also, the SFHA did not
require DEP-funded employees to document time spent on grant-related ac-
tivities; consequently, the accounting records did not show that $407,940
charged to the program was proper. The ineligible and unsupported charges
occurred because department heads were not provided with payroll data for
their review, and payroll was charged based on predetermined percentages.
Excessive charges to the DEP for payroll expenses reduce the amount of
funds available for drug elimination activities.


The notices of funding availability (NOFAs) for the drug elimination program re-
quire all grant personnel to be necessary, reasonable and justified. Excessive
staffing is not permitted. PHA employees shall be compensated with grant funds
only for work performed directly for grant-related activities and shall document the
time and activity involved in accordance with part 85 of Title 24 of the Code of
Federal Regulations (CFR), administrative requirements for grants and coopera-
tive agreements to state, local and federally recognized Indian tribal govern-
ments. Subpart 85.20 requires accounting records to be supported by source
documentation such as time and attendance records.

The NOFAs also require compliance with Circular A-87, Cost Principles for State
and Local Governments. It requires that payroll costs be distributed on the basis
of activity reports which reflect an after-the-fact distribution of the actual activity
of each employee. Budget estimates or other distribution percentages determined
before the services are performed do not qualify as support for charges to federal
awards. Where employees work solely on a single federal award, charges for their
salaries must be supported by periodic certifications that the employees worked
solely on the program.

Also, program requirements permit only direct costs under this program, and pro-
hibit indirect costs. Circular A-87 defines direct costs as those that can be identi-
fied specifically with a particular final cost objective; and indirect costs as those
incurred for a common or joint purpose benefiting more than one cost objective,
and not readily assignable to the cost objectives specifically benefited. Therefore,
costs charged must be incurred specifically to accomplish DEP objectives.




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                                                        Payroll      expenses    of
Two Employees Charged to Wrong Program
                                                        $28,951 for two employees
performing jobs unrelated to DEP activities were improperly charged to the pro-
gram. The DEP program was funding 100% of the employees’ salaries at a pro-
jected cost of $86,399 per year. One employee transferred during February 1997
from the Office of Community Relations and Involvement (OCRI) as a resident
coordinator to the maintenance department as a resident custodian performing
non-DEP activities. The SFHA continued to charge the DEP program after the
transfer for about eight months until we brought this matter to the housing author-
ity’s attention. The other employee was hired in June 1997 as a rent collection
analyst performing non-DEP functions. Personnel records showed the SFHA in-
tended to charge his salary to its general fund, but payroll records showed that all
of his salary was charged to the DEP for about three months until we brought this
to SFHA’s attention.

The SFHA budget analyst said charging these employees to the DEP was an over-
sight of the finance department. Department heads, who would be familiar with
their employees and what jobs they perform, were not provided payroll data to re-
view to ensure payroll expenses were charged to the appropriate funding source.
Therefore, no mechanism was in place to readily identify such mistakes.

                                                   In addition, payroll expenses
Administrative Leave of Former Director
                                                   totaling $56,272 over a 16-
month period for the former director of neighborhood initiatives were charged to
the DEP. The former director was on administrative leave pending a termination
hearing, and was providing no services to SFHA. The DEP was funding 60% of
the former director’s salary at a cost of $42,204 per year. Such charges are ineli-
gible under the drug elimination program since they provide no direct benefit.
Further, the SFHA has not demonstrated the reasonableness for the long period of
leave.

HUD recovery team officials made the initial decision to place the former director
on administrative leave and to start a termination hearing. However, legal counsel
advised that a proper hearing could not be held until an executive director was ap-
pointed. In November 1996, six months into the paid leave period, Ronnie Davis
became the executive director. We requested his reasons why it took another ten
months before a hearing was held to resolve the issue, but have not received an
explanation. According to the SFHA budget analyst, the former director’s salary
continued to be charged to the DEP because it was in the grant budget. The
monies used to pay the administrative leave came from the housing authority’s
general funds, whose sources include tenant rents and HUD operational subsidies.
The housing authority subsequently drew down DEP funds to reimburse the gen-
eral fund.




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The SFHA has since reduced draw downs of DEP funds for the $56,272 ineligible
payroll charges for the former director and the $28,951 payroll charged for the
two employees unrelated to the DEP. This removed all the ineligible payroll
charged for the former director from May 1996 through August 1997 (the entire
period he was paid while on leave) and also the ineligible payroll charged for the
two employees from February 1997 through September 1997. No subsequent
charges were made after September 1997 for these employees.

                                      The SFHA charged a total of $407,940 for
Unsupported Payroll Expense
                                      payroll of regular SFHA employees to the
1994 and 1995 DEP that was not supported by time records. Payroll charges to
the DEP were based on predetermined percentages. SFHA employees were not
required to document the actual time spent on DEP activities so that a proper as-
signment of costs could be made. The SFHA charged $314,881 of payroll ex-
penses to the 1994 grant for the period October 1995 through January 1997 (ex-
cluding the $85,223 ineligible amount for the former director and two non-DEP
employees as discussed above), and $93,059 to the 1995 grant for the period Feb-
ruary 1997 through July 1997, (excluding $56,480 paid to Together United Re-
committed Together (TURF) employees who spent their time solely on DEP ac-
tivities).

In 1996, the HUD recovery team found that payroll charges to the DEP were ex-
cessive and thus it revised the percentages used to allocate salaries of individual
employees to the DEP. The HUD team determined that percentages of payroll the
SFHA was charging for some positions were too high in relation to DEP activities
actually performed, and disallowed $90,322 of payroll expense charged to the
1994 DEP for the period October 1995 through March 1996. The SFHA reversed
the excess charges in April 1996 and started using the HUD-recommended per-
centages.

Subsequently, the SFHA significantly increased the percentages for three positions.
The SFHA increased the allocation to the DEP of resident management officers’
salaries from the HUD-recommended 40% to 73% percent in October 1996. The
SFHA increased the assistant director’s salary allocation from 20% to 55% in
January 1997. The SFHA increased the security specialist’s salary allocation from
20% to 70% in February 1997. The current director of the OCRI indicated that
the increases for the resident management officers were due to an increased
amount of responsibility given to them, but he did not equate this to increased
DEP activities. The SFHA budget analyst said DEP allocations are determined at
the time SFHA budgets are approved and (after the adjustment made pursuant to
HUD recommendations in April 1996) have been based according to availability of
funding, whether or not the allocation fits with the reality of employee activities.
However, this practice is contrary to federal rules requiring that payroll expense be
supported by time records showing actual time performed, and prohibiting budget
estimates or other arbitrary percentages.



                                                                                  12
                                                                     98-SF-201-1003




Also, the SFHA made arbitrary allocations of payroll charges (and some other ex-
penses) among three DEP budget categories. The payroll expense of most DEP-
funded staff was further allocated 10% to law enforcement, 70% to drug preven-
tion, and 20% to tenant patrol. SFHA and HUD team officials said the expense
allocation to the three categories was based primarily on the reasoning that some
time is spent by DEP-funded staff coordinating the three functions. We maintain
that these allocations are arbitrary and unsupported. For instance, no payroll or
other costs should have been charged to tenant patrol after July 1996 when activity
ceased. Instructions should have been provided to employees identifying specific
DEP-eligible activities so that they could identify how much of their time was
spent on such activities.

Not only were these percentages arbitrary, but whether individuals were charged at
all to the DEP was also arbitrary. Two resident management officers were 73%
charged to the grant, while a third was not charged at all even though all three had
similar responsibilities. Similarly, one resident coordinator was charged 50% while
another was charged 100%. Also, the former director was partially charged to the
grant while the current one was not. The HUD team recommended that 60% of
the director’s salary could appropriately be charged to the DEP. While this per-
centage of payroll expense was charged for the former director while he was pro-
viding no service, none of the current director’s salary was charged. According to
the SFHA budget analyst, the DEP budget would not support the salaries of two
directors.

The SFHA did not (nor did the HUD team) instruct DEP-funded employees to use
time logs to differentiate between DEP versus other activities, or assure that em-
ployees were adequately instructed on what tasks were to be funded by the DEP.
DEP-funded staff at OCRI who worked with resident groups coordinating outside
services and developing resources for public housing residents generally believed
they spent the majority of their time on DEP-related activities. The staff believed
drug issues were interwoven into all their work with resident groups, and insepa-
rable from every effort to improve the health, education, and economic status of
residents. Others, including DEP-funded resident organizers and resident coordi-
nators, were unaware of the source of monies for their salaries. Thus, the staff did
not know how to differentiate between DEP and non-DEP-related activities.

The $407,940 did not appear to be unreasonable considering the HUD recovery
team’s analysis and our interviews with employees indicating that they were per-
forming DEP-related activities. Nevertheless, SFHA needs to establish a proper
payroll distribution system to assure that costs charged to federal programs are
allowable.




                                                                                 13
                                                                     98-SF-201-1003



AUDITEE COMMENTS & OIG EVALUATION

The SFHA indicated its intention to implement a cost allocation system. SFHA
officials told us that this would include a proper payroll distribution system

While the SFHA’s written response indicated disagreement with the issue on the
eligibility of the former OCRI director’s leave, the executive director agreed this
cost was ineligible under the DEP. Still, he maintained that the 10-month period
between his appointment and his decision to terminate the administrative leave paid
to the former director was reasonable. In our opinion, however, the SFHA has not
justified such a long period.

RECOMMENDATIONS

We recommend that you:

A. Assure that the housing authority establishes a proper payroll distribution sys-
   tem which includes (1) requiring grant-funded employees to use time logs to
   document time spent on grant activities to ensure that only eligible activities
   are charged; (2) providing staff with instructions to identify which tasks are
   eligible program activities; and (3) requiring department heads to certify to the
   propriety of the payroll amounts and distribution for each payroll as they oc-
   cur.

B. Determine the propriety of using general operating funds of the housing
   authority to pay for the extensive administrative leave of the former director of
   neighborhood initiatives, and take any necessary action.




                                                                                 14
                                                                     98-SF-201-1003



Finding 3
Payments to Three Entities Were Not Supported.

Under three contracts with different community-based entities, the housing
authority paid out $20,500 for unsupported “start-up costs.” In addition, the
housing authority paid out the balance of $22,500 remaining under the con-
tract with the third entity even though performance under the contract had
hardly started. As a result, at the time of payment here was no assurance
that the funds were used in accordance with federal requirements. This oc-
curred because of poor procurement procedures and as an expedient to use
DEP funds before the 1994 grant expired.


The notices of funding availability for the DEP program require that all costs must
be reasonable, necessary, and justified with cost analysis. The notices also cite
Circular A-87, Cost Principles for State and Local Governments, and Circular A-
128, Uniform Administrative Requirements for State and Local Governments.
Some of the factors A-87 cites as affecting allowability of costs are that they be
necessary, reasonable, and allocable for the administration of the programs and
conform to any limitations or exclusions. The standards for grantee financial man-
agement systems contained in A-128 state that grantees must maintain adequate
records of expenditures and safeguard federal funds to assure they are used solely
for authorized purposes.

                                      At the time of payment, the housing author-
Unsupported Initial Advances
                                      ity’s records did not support the allowability
of initial advances made under three contracts to community-based organizations.

   ⇒ $8,000 (61 percent) for a $13,005 contract with Hunter’s Point Boys and
     Girls Club issued in January 1996.

   ⇒ $10,000 (25 percent) for a $40,000 contract with BRAVA! for Women in
     the Arts issued in February 1996. This organization subsequently provided
     a full accounting of the $40,000 after we brought this matter to the
     SFHA’s attention.

   ⇒ $2,500 (10 percent) for a $25,000 contract with Chinatown Resource
     Center and the Ping Yuen Resident Improvement Association issued in
     May 1997.

All three contracts provided for the initial advances of fixed dollar amounts to
cover start-up costs and initial program implementation. The remainder of the



                                                                                 15
                                                                    98-SF-201-1003


compensation was to be made on a cost-reimbursement basis. As discussed in
more detail in the procurement finding (page 18), the housing authority did not
obtain competitive bids or do any price or cost analysis to determine the reason-
ableness of the advance amounts; nor did it justify the need to make the advances
fixed dollar amounts that the entities were not required to account for.

                                           In July 1997, about one month after
Subsequent Unsupported Payment
                                           making the initial $2,500 advance to
the Chinatown Resource Center, the housing authority paid out $22,500, the re-
maining balance of the contract, based on an invoice from the center. Under the
contract terms, payments subsequent to the initial advance were to be made on a
cost-reimbursable basis. However, contract performance was to cover the period
from May to November 1997, and it is apparent from the invoice that the second
payment was also an advance. After we advised the housing authority of this
matter, it obtained an expense report showing actual costs through February 1998
for $16,111 of the $25,000 contract.

The second payment was due to an inappropriate management decision made to
disburse all monies in the 1994 grant before it expired in July 1997. (Funding for
this contract was programmed for the 1994 drug elimination grant.) Regulations
require that the services be provided by the grant expiration date to be eligible:
funds cannot be merely paid out or committed to be eligible. Thus, the appropriate
action would have been not to issue the contract, find an alternative source of
funding or, with HUD approval, reprogram funds among the drug elimination
grants. Since it was apparent at the time of contract award that performance
would not be completed before the expiration of the 1994 grant, the housing
authority should have addressed this issue before executing the contract.

AUDITEE COMMENTS & OIG EVALUATION

The SFHA generally agreed with this finding. Although its written response im-
plies that support has been obtained for all payments in question, SFHA officials
acknowledged to us that support still needs to be obtained for the $8,000 advance
to the Hunter’s Point Boys and Girls Club and the remaining $8,889 portion of the
Chinatown Resource Center contract.

RECOMMENDATION

We recommend that you require that the housing authority return the remaining
unsupported amounts totaling $16,889 ($8,889 of the Chinatown Resource Center
and $8,000 of the Hunter’s Point Boys and Girls Club contracts) unless it provides
documentation showing that the funds were spent for allowable costs and, for the
Chinatown Resource Center contract, if reprogramming funds among the grants is
approved.



                                                                               16
                                                               98-SF-201-1003


The audit findings on monitoring (page 23) and procurement (page 18) contain
recommendations on how to avoid future instances.




                                                                          17
                                                                       98-SF-201-1003



Finding 4
Procurement Practices Need Improvement.

The SFHA’s procurement practices for the DEP were inadequate. Documen-
tation of the procurement process was generally unavailable. Evidence was
lacking that the SFHA performed adequate cost analyses prior to entering
into contracts. The SFHA sometimes improperly inserted fixed-price portions
into contracts that should have been entirely cost-reimbursable. Sometimes
written contracts were absent. This was due to decentralization of procure-
ment operations making it difficult for the SFHA to control and monitor its
contracting activities. These weaknesses resulted in excessive and unsup-
ported costs and potentially could lead to disputes with contractors as well as
give the appearance of possible favoritism.


The notices of funding availability for the DEP require compliance with 24 CFR
part 85, administrative requirements for grants and cooperative agreements to
state and local governments. Subpart 85.36 requires grantees to maintain records
sufficient to detail the significant history of a procurement, including, but not lim-
ited to, rationale for the method of procurement, selection of contract type, con-
tractor selection or rejection, and the basis for the contract price. In addition, the
SFHA’s policy requires documentation for all procurements.

Subpart 85.36 also requires grantees to perform a cost or price analysis for every
procurement. Cost analysis involves obtaining a cost breakdown from the pro-
posed contractor(s), analyzing the labor, material, indirect costs, and profit pro-
posed, and identifying areas of questioned costs, unallowable costs, or items which
appear to be inflated or unnecessary. A cost analysis serves to assist the housing
authority in preparing for negotiations with the contractor to obtain a reasonable
price.

                                                     The SFHA did not maintain
Procurement Process Poorly Documented
                                                     documentation of the pro-
curement process for most DEP-related contracts. We reviewed available records
for nine drug prevention contracts totaling $288,172 from the 1994 DEP grant that
were monitored by OCRI. Procurement information, such as rationale for the
method of procurement, evidence of competitive award, reasons for contractor
selection or rejection, and the basis for the contract price was not available for
seven of the nine contracts. The seven contracts were issued under the supervision
of the former director of OCRI. The two contracts for which we located adequate
procurement information were made by the HUD recovery team.




                                                                                   18
                                                                       98-SF-201-1003


After the recovery team’s departure, however, the documentation problems con-
tinued under subsequent SFHA management. In March 1997, the SFHA solicited
service organizations to compete for 1995 DEP funds, but no official procurement
files to document the process were created. Some information on the process re-
sided on the electronic files of one of the OCRI panelists who evaluated the pro-
posals. The information showed 21 applicants submitted proposals and 14 were
selected initially for funding. This documentation should have been retained in of-
ficial records so that it could be readily retrieved. We noted the score sheet for the
proposals showed that one organization was not selected while three with lower
scores were. The reasons for selecting the proposals with lower scores over the
one with the higher score were not recorded. Management appeared to be un-
aware of the need to justify this procurement action or to instruct its staff to for-
mally document the solicitation process. If the SFHA were to receive a protest, it
would be difficult to justify its decisions without proper documentation, thus giv-
ing the appearance the selection was not impartial. (Due to changes in manage-
ment priorities, only two of the 14 proposals were actually funded.)

Also, a separate request for proposals for a youth and young adult employment
and training agency was issued by OCRI in June 1997. Again, no files document-
ing the process were maintained, although we located evidence in the accounting
records (not procurement records) that the SFHA did advertise in a newspaper for
proposals.

                                 We found instances where the housing authority
Absent Written Contracts
                                 permitted contractors to perform without first
entering into written contracts. Two service providers, approved to receive 1994
DEP funding in the grant plans, experienced difficulty receiving payment for serv-
ices rendered due to lack of contracts.

The San Francisco Educational Services (SFES) had provided after-school educa-
tional services at Hunter’s View under contracts for two years funded from the
1992 and 1993 DEP grants in the amounts of $36,000 and $54,000, respectively.
SFES was budgeted to receive $35,000 for Hunter’s View in the 1994 DEP ap-
proved plans. In good faith, SFES continued its operations for four months (Sep-
tember-December 1995) believing the SFHA wished them to continue. However,
the SFHA informed them that they could not be paid for services for those months
because there was no signed contract for the period in question. Payment was
made in May 1996 upon a HUD recovery team recommendation for $8,257 cov-
ering the four months. No subsequent contract was executed, and the contractor
received no additional DEP funds.

The Girl’s After School Academy (GASA), provided service for a year under an
unexecuted contract. GASA had been previously funded from the 1992 and 1993
DEP grants in the amounts of $36,000 and $60,000, respectively. GASA was
budgeted to receive $60,000 in the 1994 DEP plan. GASA continued to provide



                                                                                   19
                                                                       98-SF-201-1003


services for 1995 and expended funds, relying on SFHA staff representations that
GASA would receive funding for services performed. The housing authority ini-
tially authorized the funding under resolution number 4440 dated March 23, 1995.
However, it subsequently determined that this authorization was made without
following required procurement procedures, and did not execute a contract. A
subsequent resolution dated February 8, 1996 authorized the housing authority to
execute a contract after the fact and pay a lump-sum settlement of $60,000 to
GASA for services performed in 1995.

These contractual problems occurred under the supervision of the former director
of OCRI (prior to the arrival of the HUD recovery team). However, after the re-
covery team’s departure, the SFHA disbursed $41,200 from the 1996 DEP grant
to the SFPD’s wilderness program (a recipient selected in the March 1997 process
discussed earlier) based on its proposed budget, without a contract in place. Cur-
rent management said this was due to the service provider needing the money
quickly for program execution, and that an after-the-fact contract would be made.
Nevertheless, lack of a written contract could lead to disputes and increase risk
that funds are used for ineligible activities.

                              Even though some cost data was provided with many
Lack of Cost Analysis
                              contract proposals, there was little evidence of an
evaluation of the data. Failure to analyze contract cost proposals can cause excess
billings or inefficiencies. For example, as noted in the finding on police contract
billings (page 4), the contract for supplemental police services provided a maxi-
mum amount that was more than that required for the contracted level of service.
(Those involved in contract negotiations could not explain how the contract price
was arrived at.) Partly as a result, there were substantial excess billings.

                                         The SFHA sometimes provided contrac-
Inappropriate Form of Contract
                                         tors fixed dollar amounts to cover un-
specified start-up costs in contracts which otherwise provided compensation on a
cost-reimbursable basis. Five of the nine drug prevention contracts we reviewed
provided for initial advances to cover start-up costs under these terms; of these
nine, four contractors actually received advances. The SFHA did not obtain com-
petitive bids or do any price or cost analysis to determine the reasonableness of the
advance amounts. No contractor that received an initial advance submitted cost
data on start-up needs in their proposals for SFHA review. Further, the SFHA
could not provide information on how the amounts were determined. As noted in
another finding (page 15), three of the four did not provide support for their initial
advances (totaling $20,500). Consequently, the SFHA did not have assurance the
initial advances were used in accordance with federal requirements.

         The decentralization of procurement operations made it difficult for the
Cause
         SFHA to control and monitor its contracting activities to assure proper
procurement and contract negotiation procedures were followed. The primary



                                                                                   20
                                                                        98-SF-201-1003


SFHA contracting function was split into two components: one for procurement of
construction-related contracts and the other for procurement of commodities and
professional services and for monitoring annual contracts. Compounding this, the
various SFHA divisions often procured and contracted without the knowledge or
oversight of either procurement division. (For the DEP, the OCRI and security
divisions issued their own contracts.) Management outside the procurement divi-
sions lacked procurement expertise, and did not assure that their staffs were prop-
erly carrying out federal and SFHA’s procurement policies and requirements. In
addition, the SFHA’s procurement procedures lack written instructions for select-
ing contract type and performing cost analysis prior to contract negotiations.

At the request of the director of HUD’s Office of Public Housing, California State
Office, the Contracting Division of HUD’s Administrative Service Center III per-
formed an analysis of the SFHA’s procurement and contracting operation in Sep-
tember 1996, while the SFHA was under the control of the HUD recovery team.
HUD’s Contracting Division found SFHA’s disjointed procurement operations
caused poor coordination between the procuring department, finance, and the
board of directors, resulting in late payments to vendors, contracts never being
executed or allowed to expire without new contracts in place, and cost inefficien-
cies due to prepayments for services without negotiated contracts.

Upon the recommendation of HUD’s Contracting Division, the SFHA is in the
process of centralizing procurement activities into one office. It is intended that all
contracts will come through the new contracting office for review and assignment
of a contract number. The contracting office intends to assure that a proper bid
process is followed, all required information from bidders is received, a proper
evaluation/selection process is followed and documented, and that contracts are in
order before they are executed and contractors are allowed to start work.

AUDITEE COMMENTS & OIG EVALUATION

The SFHA did not disagree with this finding and indicated that it had implemented
or was in the process of implementing the following actions.

       •   Established and filled the position of director, contracting division, to
           oversee all procurement activities.

       •   Begun procurement training for its staff which included guidance on
           performing cost analyses.

       •   Developed a review routing form for the solicitation and award process
           which includes the requirement for contracting division approval to as-
           sure compliance with contracting procedures.




                                                                                    21
                                                                      98-SF-201-1003


The SFHA’s indicated actions and plans are generally consistent with the audit
recommendations except that the procedures need to specifically address the issues
of selecting the appropriate contract type (that is, whether fixed priced, cost reim-
bursable, hourly rate, et cetera), performing costs analysis, and determining under
what circumstances advances to contractors may be given. Housing authority offi-
cials advised us that the procedures would be appropriately revised.

RECOMMENDATIONS

We recommend that you require the housing authority to:

A. Complete implementation of a centralized contracting unit, as recommended by
   HUD’s Contracting Division. The contracting unit must assure that proper
   procurement procedures are followed, including establishing procurement files
   which document the selection process; contain the rationale for the method of
   procurement; and justify selection of contract type, contractor selec-
   tion/rejection, and basis for the contract price.

B. Revise written procurement procedures to include instructions on selecting
   contract type and performing cost analyses prior to contract negotiations.

C. Discontinue use of contract terms that provide advances that the entity is not
   required to account for.




                                                                                  22
                                                                     98-SF-201-1003



Finding 5
The Housing Authority Did Not Adequately
Monitor or Evaluate Its Program.

The housing authority had not established a process to measure DEP
effectiveness and to help assure the accomplishment of the program’s
objectives and goals. It had not established a systematic method of data
collection and analysis to measure success in achieving goals. It had not
adequately monitored its contractors. Consequently, the SFHA could not
submit to HUD progress reports with sufficient information on program
results. These conditions occurred because management lacked sufficient
appreciation or awareness of sound monitoring and evaluation practices.
While limited anecdotal evidence indicated a decrease in drug-related crime,
overall conclusions could not be drawn


The objective of the drug elimination program is to get rid of drug-related crime in
and around public housing. Applicants for grant funds must develop a comprehen-
sive program to eliminate drug-related crime in their developments. To help
achieve this desired outcome, sound management practices must be implemented.
Management needs to develop and use a system to measure program effectiveness.
The elements of such a system include the setting of performance standards.
These standards are quantifiable expressions of program objectives. Such a system
also requires monitoring progress in achieving these objectives. This involves the
collection of data and evaluation of actual versus desired results.

HUD’s regulations for the DEP are based on these principles. The NOFAs re-
quired applicants to develop performance measurements and describe evaluation
methods, including types of data to be tracked. 24 CFR subpart 761.35, drug
elimination programs, required grantees to monitor the day-to-day operations of
each program, function, or activity of the grant to assure performance goals were
achieved. This NOFA and CFR also required grantees to provide the local HUD
office with a semi-annual performance report that compares the grantees’ actual
performance to their plans.

                                           Good management practices necessi-
Evaluation Process Not Developed
                                           tate the setting of quantifiable pro-
gram objectives against which program results can be measured. In regards to the
drug elimination program, the SFHA was required to develop quantifiable objec-
tives that would demonstrate the reduction or elimination of drug-related crime.
However, the SFHA’s plans did not sufficiently quantify objectives in a way that
would measure the reduction of drug-related crime.


                                                                                 23
                                                                                    98-SF-201-1003




The 1994 plan described the proposed tasks intended to reduce drug-related crime
and included some goals in terms of levels of activity, but it did not set measurable
objectives that would relate these activities to a reduction in drug-related crime or
indicate a method for tracking the appropriate information to make this measure-
ment.

The 1995 plan stated the intention to reduce drug-related arrests2 and calls for po-
lice by 20%, and also quantified the expected numbers of prevention-type services
and participants. Yet again, methods to track information to measure the plan’s
success were not identified. Consequently, the SFHA did not report on the 1995
(nor 1994 and 1996) program’s results in relation to any decrease in drug-related
crime or even report on the levels of activities as compared to the plan. This oc-
curred because the SFHA did not establish a systematic method of data collection
and analysis to measure its program’s success in terms of decreasing drug-related
crime. Thus, the SFHA could not correlate expenditure of DEP funds to success
in achieving program goals.


2
  The NOFAs suggested tracking changes in crime statistics as one method to measure program
success. The SFHA received crime statistics quarterly which were compiled by the police de-
partment’s Housing Task Force. The Housing Task Force was funded primarily through the
DEP to provide assigned officers for supplemental police patrols at targeted sites. An earlier
contract funded through the DEP also provided Housing Task Force officers to staff resource
centers at target sites. Crime statistics generated by the Housing Task Force included quarterly
totals of felony, misdemeanor, and narcotics arrests, number of tenants arrested, weapons confis-
cated, moving and parking violations, calls for service, incident reports, vehicles towed, dogs
removed, and community meetings. The SFHA has used some of these statistics for inclusion in
DEP grant applications to indicate a crime problem, but did not track them on an on-going basis
to analyze crime trends to measure the success of its DEP. Further, the statistics may only be
good for measuring police activities rather than progress in reducing drug-related crime.

While grant rules call for tracking of crime and other statistics as a method to measure program
success, the SFHA must take care to develop a system that can determine if changes in drug-
related crime are a direct result of its DEP initiatives. Also, statistics collected must be appropri-
ate for use in planning and formulating strategy. For example, a police lieutenant in the narcot-
ics division told us that it is not possible to correlate arrest rates with drug-related crime rates.
He believed the number of arrests is directly related to the extent of the police coverage, which
depends on available funding. He did not believe an increase or decrease in the number of arrests
was indicative of an increase or decrease in crime rates. Rather, an increase in arrests generally
means more money was available to permit more time and effort to be expended, resulting in
more arrests. Likewise, a decrease in arrests generally means that less work is done in the area,
rather than a decrease in crime rate.

In addition, a knowledgeable HUD official indicated that a change in the number of arrests is not
indicative of a change in drug-related crime rates, but that number of calls and types of calls to
police can be used as indicators. The official said that some housing authorities are having suc-
cess tracking drug-related crime by providing training to housing managers and resident councils
on how to report the number of incidents.




                                                                                                  24
                                                                     98-SF-201-1003


                                 The 1996 plan, submitted by the HUD recovery
Unused Evaluation Tools
                                 team, described proposed programs in detail and
included some goals in terms of levels of activity, but again did not set measurable
objectives that would relate program results to reduction in drug-related crime.
However, the 1996 application described two tools for evaluation purposes in-
tended to gather data to analyze and measure program success. Nevertheless, the
SFHA did not use them when not under control of the HUD recovery team. The
first evaluation tool was a resident opinion survey that assessed resident percep-
tions on the level and type of security needs at SFHA properties. Conducting sur-
veys at periodic intervals would allow evaluation of programs implemented for the
purpose of improving the identified problems. The second evaluation tool was a
form to be filled out by each client using services at the resource centers, which
would provide the SFHA statistics on the number of residents served, the types of
services received, and the totals for each service type. This data would provide
information useful in developing future plans for resource centers.

The resident opinion survey was taken at two developments during the summer of
1996 when the SFHA was under the control of the HUD recovery team. The sur-
vey collected resident opinions regarding security and crime on housing authority
property. We obtained the results from the recovery team’s report on SFHA’s se-
curity and safety issues, entitled An Assessment and Blueprint for Security and
Safety for the San Francisco Housing Authority. The results indicated that 40%
and 33% of respondents, respectively at the two developments felt “very unsafe”
inside their units, while 63% and 60% felt “very unsafe” outside their units. Also,
53% and 64%, respectively, felt crime was a major problem, with drug use as the
biggest crime problem. However, the Office of Community Relations and In-
volvement (OCRI) did not make use (or even have possession) of the results of the
survey or perform any other type of program evaluation.

Current management indicated that the form planned for tracking client use of re-
source center services was not being used. Management said resource centers did
not yet have a good tracking system for recording use of the facilities.

                                   Sound management practices, codified in 24
Monitoring of Contractors
                                   CFR subpart 761.35, require managing the day
to day operations of grant and subgrant-supported activities to assure compliance
with applicable federal requirements so that performance goals are achieved. In-
formation obtained from monitoring grant-funded activities allows the grantee to
assess whether the activity is achieving the intended results.

However, SFHA monitoring of 1994 DEP contracts was minimal. Twelve con-
tracts were funded by the 1994 grant: nine were for drug prevention services, two
were for police services, and one was for a private security service. Evidence of
substantive monitoring was lacking in all cases. Monitoring files were missing in-
formation necessary to assess the contractors’ performance. For example, seven



                                                                                 25
                                                                        98-SF-201-1003


drug prevention contracts required the contractor to submit quarterly reports that
summarized the progress of the services performed, including type of service,
number of residents served, and the personnel who performed the services. How-
ever, no quarterly reports were on file for four of the seven, and the three con-
tractors that submitted one or more reports did not do so timely or consistently.
The SFHA could not properly monitor contractor performance without such in-
formation. In fact, no contract file documented an assessment of the contractor’s
program to determine program effectiveness in accomplishing stated goals. Fur-
ther, in at least five cases, monitoring files did not contain copies of the contracts.

The 1994 DEP drug prevention contracts were monitored principally under the
direction of the former director of OCRI. The subsequent director received tech-
nical assistance from the HUD recovery team, including information on the overall
requirements for managing DEP grants and developing a monitoring system. The
HUD team provided the director a mock-up of a contract/grant file and a spread-
sheet to track grant funds, and discussed database requirements to assist in devel-
oping management reports for monitoring of OCRI fiscal activities.

                                     Nevertheless, the last of the 1994 DEP
HUD Recovery Team Recom-
                                     contracts administered under the subse-
mendations Not Followed              quent director (a $25,000 mini-grant to the
Chinatown Resource Center) was inadequately monitored. No monitoring file was
available at the time of our review. The SFHA paid the contractor the entire
$25,000 four months prior to the end of the contract term, without obtaining any
cost-supporting documents or quarterly activity reports. (See finding on unsup-
ported payments to community-based entities on page 15.)

Additionally, the SFHA inadequately monitored two police contracts and approved
invoices which billed at improper rates and level of service. (See finding on over-
payments to the police on page 4.)

                      HUD required specific elements, described in CFR Title
Progress Reports
                      24, subpart 761.35, to be included in semi-annual perform-
ance reports to measure the grantee’s performance against its plan. These in-
cluded:

       •   change or lack of change in crime statistics or other indicators, and an
           explanation of any difference,
       •   successful completion of any of the strategy components identified in
           the applicant’s plan,
       •   a discussion of any problems encountered in implementing the plan and
           how they were addressed,
       •   an evaluation of whether the rate of progress meets expectations,
       •   a discussion of grantee’s efforts in encouraging resident participation,
           and



                                                                                    26
                                                                               98-SF-201-1003


        •   a description of any other programs that may have been initiated, ex-
            panded, or deleted as a result of the plan, with an identification of the
            resources and the number of people involved in the programs.

                           The SFHA submitted performance reports semi-annually
Incomplete Reports
                           to HUD; however, the narratives generally lacked the
required elements necessary to evaluate the SFHA’s progress in reducing or elimi-
nating drugs from their developments. Progress reports for the 1994, 1995, and
1996 DEP grants submitted under the HUD recovery team for the period January
through June 1996 contained some elements, including descriptions of drug pre-
vention services, levels of participation, and crime statistics for the period (al-
though changes in crime statistics were not discussed). However, reports for the
subsequent two reporting periods through June 30, 1997 submitted under subse-
quent management merely repeated some of the descriptions provided in the previ-
ous reports, adding little new information. These subsequent reports did not in-
clude explanations of changes in crime statistics or other indicators, explain any
differences to the plan, describe problems in implementation and solutions, or
evaluate rate of progress against expectations.

Further, performance reports for the period ending June 30, 1997 did not explain
changes to the plans, including contracting for a private security service and im-
plementing an on-site patrol/intervention program (TURF) with funds originally
approved for drug prevention activities and a tenant patrol. Nor did the SFHA
prepare and provide to HUD quantifiable objectives for revised plans in order to
measure their success.

                                          HUD developed the Outcome Monitoring
Outcome Reports Not Prepared
                                          Form to enable housing authorities to
collect relevant data to measure the impact of DEP funds. The form required
tracking of crime statistics specific to the housing developments targeted by the
DEP grants; resident participation rates in DEP-funded activities; screening of ap-
plicants and lease enforcement; linkages the grantee has to external institutions
also working on anti-drug and anti-crime issues in public housing; and overall resi-
dent and staff satisfaction with local safety. Although HUD required this informa-
tion semi-annually, the SFHA never submitted the form.3

           SFHA management lacked sufficient appreciation or awareness of
Causes
           sound program monitoring and evaluation practices. If sound practices
were in effect, the SFHA would have established a system to measure the effec-

3
  Notice PIH 94-83 (HA), New Semi-Annual Form for Public Housing Drug Elimination Pro-
gram Outcome Monitoring, HUD-52356 required grantees to submit Outcome Monitoring Forms
as a part of their semi-annual performance reports. The requirement was in effect from Novem-
ber 1994 through July 1997. HUD is reformulating a standardized semi-annual performance
report for evaluation of housing authorities’ drug elimination programs that is scheduled to be
available by the end of FY 1998.



                                                                                            27
                                                                     98-SF-201-1003


tiveness of its drug elimination program even if not specifically required by HUD’s
rules and regulations. SFHA officials overseeing DEP-funded programs seemed
unaware of the need for an evaluation method: management apparently believed
implementation of programs was sufficient. Further, management had not pro-
vided written procedures for staff monitors to follow for effective program over-
sight and evaluation of contractor activities. Also, the SFHA staff responsible for
completing progress reports said they were unaware of the required elements for
progress reports.

                                                 We spoke with three SFPD offi-
Limited Anecdotal Evidence Indi-
                                                 cials, one SFHA official, and six
cated Decrease in Drug-related Crime             residents, and all believed that
drug-related crime has decreased in public housing developments in San Francisco.
Residents believed the following initiatives contributed to the reduction of drug-
related crime: (1) recent increases in provisions for security, including gated-
communities, private security services, SFPD, and TURF (TURF had mixed re-
views), (2) programs which employ residents as landscapers, painters, lead abators,
TURF members, and so on as well as (3) on-going after-school tutoring, job
training, recreational outings, computer training, and other improvement programs
for residents. Of these initiatives named helpful by residents, those funded through
DEP were SFPD, private security services, TURF, and to a much smaller extent,
resident programs. (Resident programs comprised only 17% of the 1994 grant;
6% of the 1995 and 1996 grants.)

                                                 Nevertheless, without adequate
Perceived Lack of Accomplishment Led
                                                 monitoring or evaluation of
to Disapproval of Additional Funding             contractors and its DEP pro-
gram in general, the SFHA could not show whether or not its use of grant funds
resulted in the reduction of drug-related crime in public housing. Further, the
SFHA could not evaluate its program to identify unsuccessful strategies or to jus-
tify modifications made to original plans. In addition, HUD did not receive the
data it needed to evaluate SFHA’s performance and assure compliance with grant
objectives. Consequently, HUD perceived that the SFHA lacked an adequate
evaluation system and had not implemented planned programs timely. That as-
sessment played a role in HUD’s decision to turn down SFHA’s 1997 application
for additional DEP funds.

AUDITEE COMMENTS

The SFHA indicated concurrence with this finding, stating that it recognizes the
need to strengthen program evaluation and monitoring functions and that it is in
the process of consolidating grant activities with the intent to formalize effective
evaluation and monitoring processes.

RECOMMENDATIONS


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                                                                    98-SF-201-1003




We recommend that you assure that the housing authority:

       A. Establishes a method to measure the effectiveness of its DEP by
          adopting measurable and relevant performance goals that allow evalua-
          tion of program success. Evaluations should be sufficient to indicate if
          modification of activities is needed to make them more successful and
          to identify unsuccessful strategies. If needed, the SFHA should obtain
          support and advice under the public housing drug elimination technical
          assistance program.

       B. Provides written procedures for monitoring contractors that call for
          documenting oversight and evaluation of their activities. Implement
          HUD recovery team recommendations for monitoring contractors.

       C. Ensures that appropriate staff members are fully aware of the pro-
          gram’s reporting requirements and includes the required information in
          performance reports.




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Finding 6
Approval for Program Changes Was Requested
After the Fact.

The SFHA made substantial changes to its 1994, 1995, and 1996 drug elimi-
nation programs. However, it did not seek or obtain HUD approval as re-
quired prior to implementing the changes. This occurred because SFHA of-
ficials did not appreciate the need to obtain HUD’s advance approval. As a
result, HUD was not given the opportunity to evaluate the revised plans be-
fore they were put into effect. Also, the SFHA put itself in possible fiscal
jeopardy if HUD disapproved the changes.


NOFAs require compliance with 24 CFR part 761, drug elimination programs.
Subpart 761.20 states that DEP-funded programs must be part of a comprehensive
plan for addressing the problem of drug-related crime. Subpart 761.30 states that
if the grant plan, approved budget, and timetable, as described in the approved ap-
plication, are not operational within 60 days of the grant agreement date, the
grantee must report the revised plan and timetable to HUD for approval. HUD
may impose sanctions if the grantee proposes substantial changes that, if originally
submitted, would have resulted in the application not being selected.

                        The SFHA made substantial changes to plans approved
Changes to Plans
                        upon issuance of the grants, principally by decreasing drug
prevention activities and increasing security. These changes were the result of
needs perceived by current management (who had not prepared the original plans)
and because the strategy to use tenant patrols was considered to be unfeasible.

   ⇒ 1994 DEP. Instead of forming a tenant patrol and using all funding
     planned for drug prevention, it used $323,840 for private security services,
     $78,930 for additional law enforcement, and $44,426 for additional pro-
     gram administration. The reprogramming represented 27 percent of the
     total grant.

   ⇒ 1995 DEP. Instead of forming a tenant patrol and funding 14 community
     organizations for various drug prevention activities, it funded only one
     community organization, and used $439,392 for private security service,
     $191,640 for additional law enforcement, and $56,480 for TURF. The
     amount reprogrammed was 41 percent of the grant.

   ⇒ 1996 DEP. Instead of forming a tenant patrol and funding five community
     organizations and a substance abuse counselor as planned, it funded only


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                                                                     98-SF-201-1003


       two community organizations, and management has indicated plans to re-
       program the remaining funds for the private security service and for TURF.
       (Ninety-four percent of grant funds remained to be spent at the time of our
       review.)

                                      The SFHA did not submit revised plans
Revised Plans Submitted Late
                                      timely to HUD. Instead, the SFHA incurred
expenses for the revised activities and subsequently requested HUD’s approval.
For example:

•   The SFHA began solicitation for an on-site patrol/intervention program
    (TURF) in June 1997. Forty-two TURF members were put on SFHA payroll
    beginning July 1997. The SFHA did not request reprogramming of 1995 DEP
    funds for these new positions until October 1997, when HUD approved the
    changes. Therefore, the SFHA conceived these changes to its plans at least
    five months before alerting HUD, and was expending funds for the activity for
    about four months before HUD’s approval of the change.

•   The SFHA issued an emergency contract for security services beginning in
    March 1997. The SFHA alerted HUD of its need to reprogram 1994 DEP
    funds for this purpose in April 1997. HUD responded that it needed additional
    information from the SFHA before approving the reprogramming. HUD ap-
    proval did not occur until July 24, 1997, only six days before the grant’s expi-
    ration. Therefore, the SFHA was expending funds on this activity for the 1994
    grant about four months before HUD’s approval. Also, the security services
    continued into the 1995 grant. The SFHA did not request or obtain HUD
    permission to use 1995 grant funds until October 1997, seven months after it
    initiated the new plan (under the 1994 grant) and three months after security
    services were charged to the 1995 grant.

SFHA officials did not appreciate the need to obtain HUD’s advance approval.
They decided to wait until knowing what had been spent and therefore the actual
amounts to reprogram. They were concerned that reprogramming at an earlier
date could require another revision to have to be made later on. The SFHA did
not formulate new budgets early on to reflect revisions to the plans and instead
took a “wait and see” attitude.

Since the SFHA did not submit revised plans before their implementation, HUD
had no opportunity in advance to determine their suitability. Although HUD ap-
proved the changes, the SFHA put itself in possible fiscal jeopardy if HUD had
disapproved the changes after the SFHA had spent the money. In this regard, we
note that HUD turned down the 1997 grant application. The 1997 plan budgeted
almost half of the funds for program administrators, the next largest amount for
TURF, and only six percent of the grant for prevention activities.




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AUDITEE COMMENTS & OIG EVALUATION

The SFHA’s written response indicated that it appreciated the need to obtain HUD
approval in advance, yet it needed to take extraordinary steps in response to emer-
gency conditions for resident safety and to avoid losing unspent DEP funds. The
SFHA attributed the slow implementation of its program to the mismanagement
that resulted in the 1996 HUD recovery effort. The executive director expressed
his belief at the conference that verbal HUD approval was obtained prior to incur-
ring expenses for activities outside the approved program, until we pointed to
documents showing otherwise.

In our opinion, the program changes occurred largely because the perceptions and
priorities of the SFHA’s new management differed from previous management,
rather than a significant change in crime environment at the housing authority’s
housing developments. Further, we maintain that proper coordination with HUD
is necessary even under emergency conditions.

RECOMMENDATION

We recommend that you impose appropriate sanctions on the housing authority if,
in the future, it does not obtain HUD approval prior to implementing revised plans.




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                                                                      98-SF-201-1003




Management Control
                            In planning and performing the audit, we considered
Controls Considered
                            the management control systems used by the San Fran-
cisco Housing Authority to determine the audit procedures and not to provide as-
surance on management control. Management control is the process effected by
an entity’s board, management, and other personnel, designed to provide reason-
able assurance for achieving objectives for program operations, validity and reli-
ability of data, compliance with applicable laws and regulations, and safeguarding
resources.

The following control systems were relevant to the audit objective.

           ⇒   Expenses and disbursements
           ⇒   Revenues and receipts
           ⇒   Personnel and payroll operations
           ⇒   Procurement
           ⇒   Contract monitoring
           ⇒   Program evaluation
           ⇒   Reporting to HUD

                                      To design audit procedures, we obtained an
Audit Procedures Were Based
                                      understanding of the control structure for
on a Risk Assessment                  the above systems and determined the risk
exposure. We concluded that the audit would be performed more efficiently by
doing substantive tests without reliance on management control. Therefore, we
did not necessarily make a complete assessment of control design or determine
whether policies and procedures had been placed in operation.

A significant weakness exists if management control does not give reasonable as-
surance that control objectives are met. Observed weaknesses with procurement,
contract monitoring, program evaluation and reporting, and payroll allocation are
discussed in the report’s findings.




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                                                                                98-SF-201-1003




Appendices
Appendix 1

Schedule of Ineligible & Unsupported Amounts and
Efficiencies

               Issue            Ineligible Unsupported                Efficiencies
                                Amounts      Amounts
                                           1
         Finding 1 – po-          $339,466     $33,0382                     $28,4583
         lice contracts
         Finding 2 –               $85,2234                                 $86,3995
         payroll
         Finding 3 –                                     $16,8896
         community-
         based entities

Ineligible amounts obviously violate law, contract, HUD or local agency policies
and regulations.

Unsupported amounts do not obviously violate law, contract, policy or regulation
except for the absence of evidence to show that the amounts conform with re-
quirements.

Efficiencies result from actions by management to prevent or avoid future im-
proper or unnecessary obligations or expenditures.



1
  This consists of $333,950 (total exception of $366,988 less unsupported amount of $33,038) for
the housing task force contract and $5,516 for the resource center contract.
2
  This represents regular overtime charged under the housing task force contract.
3
  This represents the balance of the housing task force contract not billed after the police were
advised of the overbilling.
4
  This consists of $28,951 for two employees erroneously charged to the DEP program and
$56,272 of administrative leave for the former director of neighborhood initiatives.
5
  This represents the annual cost of the two employees erroneously charged to the program whose
charges to the program were stopped after the housing authority was advised of the error.
6
  This consists of $8,889 of the amount paid to Chinatown Resource Center and $8,000 paid to
Hunter’s Point Boys and Girls Club.



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                                                                    98-SF-201-1003



Appendix 2

Auditee Comments




[Note: Due to their volume, exhibits referenced in the written responses are not
included here. The exhibits to the responses will be provided upon request.]



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Appendix 3

Distribution

Director, Office of Public Housing, California State Office, HUD
Secretary’s Representative, California State Office, HUD
Director, Accounting Division, California State Office, HUD
Director, Administrative Service Center, Colorado State Office, HUD
Director, Contracting Division, Administrative Services Center 3, Denver, HUD
Office of Comptroller, Texas State Office, HUD
Deputy Secretary, HUD
General Deputy Assistant Secretary for Public and Indian Housing, HUD
Director, Office of Troubled Agency Recovery, HUD
Director, Office of Crime Prevention and Security, HUD
Assistant Secretary for Congressional and Intergovernmental Relations, HUD
Chief of Staff, HUD
Assistant Secretary for Public Affairs, HUD
Counselor to the Secretary, HUD
General Counsel, HUD
Senior Advisor to the Secretary for Communications and Policy, HUD
Assistant to the Secretary for Labor Relations, HUD
Office of Public and Indian Housing Comptroller, HUD
Director, Office of Capital Improvements, HUD
Assistant to the Deputy Secretary for Field Management, HUD
Chief Financial Officer, HUD
Deputy Chief Financial Officer, HUD
Director, Office of Budget, HUD
Acquisition Librarian, HUD
U.S. Attorney, Northern District of California
Committee on Governmental Affairs, U.S. Senate
Government Reform and Oversight Committee, U.S. House of Representatives
Subcommittee on General Oversight and Investigations, U.S. House of
       Representatives
Director, Housing and Community Development Issue Area, U.S. General
       Accounting Office
San Francisco Housing Authority
San Francisco Police Department




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