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177-2000 LTC CITY OF MIAMI BEACH CITY HALL 1700 CONVENTION CENTER DRIVE MIAMI BEACH, FLORIDA 33139 http:\\ci.miami-beach.fl.us L.T.C. No. 177-2000 LETTER TO COMMISSION September 14, 2000 TO: Mayor Neisen O. Kasdin and Members of the City Commission Jorge M. Gonzalez \,' ~ City Manager (jq..JV' (j FROM: SUBJECT: Hun AUDIT OF HOUSING AUTHORITY Attached please find the OlG draft audit report regarding the Housing Authority forwarded for our review. In light of the timeframes set forth for a response, the Administration will meet with the Housing Authority immediately to address the findings therein. If you have any questions, please contact me. JMG/C~rar F:\CMGR\$ALL\RAR\LTClHUDAUDIT.HA attachment c: Christina M. Cuervo, Assistant City Manager Richard Barreto, Chief of Police Mayra Diaz-Buttacavoli, Assistant City Manager Kevin Smith, Director of Parks and Recreation Miguell Del Campillo, Housing Division Director BOARD OF COMMISSIONERS CHARLES W. BURKETT. IV CHAIRMAN JONATHAN D. SetOff VICE-CHAIRMAN RUTH E. PASARELL COMMISSIONER MARIA SEATRIZ GUTIERREZ COMMISSIONER STEVEN E. CHAYKIN COMMISSIONER co ('oJ CO . , -- , 0"") - C;,. L I v'J --, ....J THE HOUSING AUTHORITY OF THE CITY OF MIAMI BEACH, FLORIDA EXECUTIVE OFFICE 200 ALTON ROAD MIAMI BEACH, FLORIDA 33139-6742 TELEPHONE: 305.532.6401 FAX: 305-674.8001 TDD: 305-672.5501 LARRY P. SHOEMAN EXECUTIVE DIRECTOR Date: September 12, 2000 To: Christina M. Cuervo Assistant City Manager .4;:2' Larry P. Shoeman, Executive Director 'f- ,J From: Reference: OIG Draft Audit Report We have now received the above referenced document and related supporting attachments from the Office of Inspector General, U. S. Department of Housing and Urban Development. I am enclosing a copy of this report and documents for your reference. Upon review, you will note that two of the four findings (#'s 1 and 2) directly impact the City of Miami in both determinations of culpability and proposed remedy. As the OIG's proposed recommendations to remedy include a substantial recovery of City funds for "Questionable Activities", I believe it would be mutually beneficial to both the City and the Authority to re-visit our collective documentation for each of the three disallowed cost programs. The IG review schedule/table of the Authority-to- City payment history is included in the attached, which provides a record of the payment transactions. I have been advised that the IG expects a reply from this agency not later than September 19, 2000. The sooner we can get together to develop a mutually acceptable response, the better. I look forward to hearing from you soon. Ene. U.S. De_." or Housing and Urbon Development DIstrIct 0fI\ce or the Iospeetor General Ollke or Audit, Box 42 Richard B. RusseD Federal BuiIdiag 7S Spring Street. SW, Room 330 Atlanta, GA 30303-3388 (404) 331-3369 August 24, 2000 Mr. Larry Shoeman Executive Director Housing Authority of the City of Miami Beach 200 Alton Road Miami Beach, Florida 33139-6742 Dear Mr. Shoeman: We have completed an audit of the Housing Authority of the City of Miami Beach. Enclosed is a copy of the draft audit report for your review. Before issuing our final report, we would like to hold an exit conference with you and HOD program officials to discuss the findings and recommendations and answer any questions you may have. We will contact your office soon to arrange a convenient time for this meeting. Also, after the exit conference, we will give you an opportunity to submit your official comments in writing. The fmal audit report is subject to public release under the Freedom of Information Act. Therefore, we encourage you to provide us with written comments for inclusion in the published report. We request that your comments be provided to us within 2 weeks after the exit conference and be in electronic format. Please be advised that draft audit reports do not necessarily contain final conclusions and are subject to revision. They are made available solely to officials responsible for their review and comments. Officials who receive draft reports are required to exercise due care to avoid premature or otherwise improper disclosure of the information contained in them. Drafts may not be released without our concurrence and reproduction of the document without our knowledge or consent is prohibited. If you have any questions, please contact James D. McKay, Assistant District Inspector General for Audit, or Senior Auditor Narcell Stamps at (404)331-3369. Sincerely. cr' -LV.#..' 'me./t..r ftt Nancy H. Cooper District Inspector General for Audit Southeast/Caribbean Enclosure TO: Karen Cato- Turner, Director, Office of Public Housing, Florida State Office, 4DPH FROM: Nancy H. Cooper District Inspector General for Audit-Southeast/Caribbean, 4AGA SUBJECT: Housing Authority of the City of Miami Beach Miami Beach, Florida We completed an audit of the Housing Authority of the City of Miami Beach, Florida (HACMB). We conducted the audit pursuant to a request by your office dated July 9, 1999. This report contains four fmdings that require follow-up action by your office to ensure implementation of appropriate corrective action by the HACMB. Within 60 days please give us a status report, for each recommendation in this report, on: (1) the corrective action taken; (2) the proposed corrective action and the date to be completed; or (3) why action is considered unnecessary. Also, please furnish us copies of any correspondence or directives issued because of the audit. Should you or your staff have questions, please contact James D. McKay, Assistant District Inspector General for Audit, or Senior Auditor Narcell Stamps at (404) 331-3369. DRAFT\ Executive Summary We completed an audit of the Housing Authority of the City of Miami Beach (HACMB). We conducted the audit in response to a request by the Department of Housing and 'Urban Development, Office of Public Housing. We reviewed certain aspects of the HACMB Section 8 and public housing operations. Our primary objectives were to determine if the HACMB complied with HOD and or State of Florida requirements for: (1) Section 8 expenditures for inter-local projects with the City of Miami Beach; (2) Section 8 expenditures for construction of a single parent family housing and resource center; (3) Section 8 rent reasonableness and rent increases; and (4) procurement and general disbursements of public housing funds. The audit disclosed violations of requirements with regards to each audit objective and over $2.8 million in questioned costs. These conditions resulted from the HACMB's mismanagement of its Section 8 and public housing programs and its financial affairs. Specifically, the HACMB: . Expended $795,178 of its Section 8 reserves for questionable activities provided through contracts with the City of Miami Beach. The HACMB executed a series of inter-local agreements (contracts) with the city whereby the HACMB paid the city for police protection, recreation, child-care, and code enforcement. The costs for the child care activity were reasonable and they met the standards for eligibility. However, we questioned the reasonableness and necessity of the $795,178 paid for police protection, code enforcement and recreation. The costs were for public services the city should have provided from its local tax revenues. . Wasted over $2 million in a failed effort to provide housing and social services due to inadequate planning and management of human and fmancial resources. In 1995 HOD waived regulations to allow HACMB to refund bonds to refinance Rebecca Towers North on the condition that HACMB use a portion of the bond proceeds to construct a women and children housing and resource center. The center was to house battered women and children. The HACMB spent over $2 million for site acquisition, site improvements, architect fees, city fees and various preliminary costs for the planned project. However they still had not . broken ground to construct the building needed to provide the housing and space for the social services. The project had been delayed for over five years and the HACMB had lost or was at risk oflosing almost all of the $5.8 million originally committed to fund the project. The HACMB had not developed final plans to construct and operate the center. By the time we completed our on-site review the city had informed the HACMB that it was considering a road construction project that may impact the site planned for the center. The city's project may prevent the HACMB from DRAFT\ 2 constructing the project on the site. We question whether the HACMB can recover any significant portion of the $2 million wasted on the project. . Did not adhere to HUD requirements designed to assure the reasonableness of Section 8 rents. The HACMB also did not timely execute new leases for tenants who moved from one assisted unit to another and pay tenants the amounts by which their utility allowances exceeded the family's contribution for rent. As a result, there was inadequate assurance that HUD subsidized reasonable Section 8 rents and that tenants received the full benefit of their utility allowances. We noted some cases where the HACMB and owners provided false representations concerning rent reasonableness. These conditions caused HUD to pay $9,267 in excessive subsidy. . Had not implemented corrective actions recommended by past reviewers of its operations to comply with procurement requirements. For instance, subsequent to being put on notice concerning violations of procurement requirements, the HACMB acquired legal services and small purchases without adequate assurance that they obtained the most advantageous cost from the most qualified sources. We provided copies of the draft report to the HACMB and HUD's Florida State Office. We also discussed the draft report with HACMB officials at an exit conference on August xx, 2000 and with HUD officials on August xx, 2000. The HACMB provided written responses to the draft report on August xx, 2000. The HACMB generally with the fmdings. We considered HACMB and HUD responses in fmalizing the report. The HACMB's comments are summarized within each finding and included in their entirety in Appendix B. 3 \DRAFT\ Table of Contents Management Memorandum Executive Summary Introduction Findings 1 Section 8 Reserve Funds Used to Pay for Questionable Activities 2 Housing and Social Services Not Provided 3 Mismanagement of Section 8 Program 4 Need to Improve Procurement Administration Management Controls Follow-Up on Prior Audits Appendices A Scheduled of Questioned Costs B Auditee Comments C Distribution Abbreviations CFR ED HACMB HUD IPA Code of Federal Regulation Executive Director Housing Authority of the City of Miami Beach U.S. Department of Housing and Urban Development Independent Public Accountant 4 III 1 DRAFTI Background The Housing Authority of the City of Miami Beach (HACMB) is a public body organized under Section 421 of the Florida State Statutes. As of July 2000, the HACMB administered 2,943 housing units for low to moderate income families. The HACMB owned and operated a 200-unit conventional public housing project for the elderly; a 200 unit Section 8 new construction project; and a 16 unit affordable housing project. The HACMB also administered 1,856 Section 8 vouchers; 346 Section 8 certificates; and 131 Section 8 moderate rehabilitation units. In addition, the HACMB was the contract administrator for three Section 8 substantial rehabilitation projects that consisted of approximately 194 units. The HACMB was governed by a five-member Board of Commissioners who were appointed and served pursuant to Florida State Law. The Board of Commissioners were primarily responsible for ensuring the integrity of the HACMB's programs and operations; fiscal management; and hiring the Executive Director (ED). The ED was responsible for the day-to-day management of the HACMB, implementation of Board policies and procedures, and overseeing HACMB staff that consisted of approximately 44 employees. History Prior to and during our field work, several independent entities reviewed the HACMB operations and detected serious problems related to its administration of programs and its fmancial affairs. The different reviewers reported similar deficiencies in the HACMB's operations. Specifically: . In 1999, the HACMB hired a consultant to conduct a review of its financial operations, accounting department, and Section 8 department. The consultant reported several financial management deficiencies and gross inadequacies in determining rent reasonableness and lack of procedures in its Section 8 department. . In February 2000, HACMB's independent public accountant (lPA) issued a report on the results of an audit of the HACMB's operations for the fiscal year ended June 30, 1999. The report contained 37 findings that included issues concerning Section 8 and financial management. HACMB's IPA audit for the fiscal year ended June 30, 1998, contained a fmding on procurement issues. . In February 2000, HUD's Office of Public Housing conducted an In-depth Consolidated Management Review of HACMB's operations (report issued June 22, 2000). The report contained 30 findings, including several related to Section 8 issues. Due to the seriousness of the Section 8 issues, HUD placed the HACMB's Section 8 program on a one-year probation. 5 ~rclt The following table shows the similarity of findings cited by the various reports: Consultant's 1998 and HUD's June August 1999 1999lPA 2000 Findings I Concerns Report Audits Report Section 8 Rent Reasonableness I Rent Increase ,( ,( ,( Utility Allowance I Reimbursement ,( ,( HQS / Abatement of HAP ,( ,( Lack of procedures ,( Incomplete files / Waiting List ,( ,( Financial Management Cash Controls I Lack of Safeguards ,( ,( Cost Allocation / Budgeting I ,( ,( ,( Monitoring Accounting and recording of Expenses, ,( ,( ,( Assets, and Individual Funds Segregation of Duties ,( ,( Procurement ,( ,( Lack of policies and procedures ,( ,( HACMB recently developed an action plan to address findings and concerns cited in the HUD report. However, it had not prepared a written plan with target dates to address the IPA findings. Following these reviews, the HACMB initiated several organizational and operational changes in an effort to improve performance. During our audit, the HACMB hired a new ED (who reported for work on July 17, 2000) and Finance Director, and initiated measures to address problems within its Section 8 department. For instance, the HACMB assigned its Executive Secretary to oversee both the Section 8 leasing and ~nspection departments. The HACMB also retained the services of a consultant to help tlie new Section 8 manager address the issues raised by HUD. However, as cited in our fmdings, we observed a need for continued improvement. Audit Objectives; Scope, and Methodology We conducted the review based on an audit request from HUD concerning the reasonableness of Section 8 contract rents. In planning the audit, we considered the fmdings and concerns cited in past reviews of HACMB's operations by HUD, independent auditors, and consultants. We developed our audit objectives to further examine certain issues, in addition to rent reasonableness, that were subject to waste and abuse and to determine if such conditions had occurred. DRAFT 6 Our primary objectives were to determine if the HACMB complied with HUD and/or State of Florida requirements for: (I) Section 8 expenditures for inter-local projects with the City of Miami Beach; (2) Section 8 expenditures for construction of a single parents and family housing resource center; (3) Section 8 rent reasonableness and rent increases; and (4) procurement and general disbursements of public housing funds. To accomplish the audit objectives, we examined records maintained by the HACMB, City of Miami Beach, landlords, HUD, and HACMB's independent auditor. We also interviewed HACMB (past and present), City, and HUD officials as well as landlords, tenants, and consultants. We visited housing units to determine their condition but we did not conduct a detailed review for housing quality standards (HQS) because the conditions we observed were similar to those included in recent reports by HUD and a consultant. Those reports contained appropriate recommendations for corrective action. While conducting the review, we used judgmental sampling methods. Specifically, we: . Examined 20 tenant files for rent comparability and or rent increases. . Visited the offices of five landlords and reviewed records related to assisted and unassisted rents charged at 11 projects that consisted of 163 units. . Interviewed 27 tenants. We asked questions to determine the propriety of the tenant ~election for Section 8 assistance; amount of subsidized rent; tenant's rent payments to landlords; and payments to landlords for extra services (e.g., furniture or other fees). In regards to fees for extra services, we also asked the tenants to confirm whether or not they received anything of value in return for the fees. . Walked through 40 units to determine their general condition and or to determine if the unit bedroom size agreed with what the files showed. · Examined 78 percent of the $938,872 paid to the city for activities funded through inter-local agreements and assessed the progress of HACMB's efforts to construct the single parents family housing and resource center. . Tested disbursements from the low income housing program that equaled or exceeded $1,000 for the period December 1999 through May 2000. We performed the on-site review in September 1999 and January through July 2000. The audit generally covered the period July 1, 1997, through December 31, 1999. However, we extended coverage to other periods when needed to ensure full development of the issues cited in the findings. We conducted the audit in accordance with generally accepted government auditing standards. 7 DRAffl Finding 1 Section 8 Reserve Funds Used to Pav for Ouestionable Activities The HACMB spent $795,178 in section 8 reserve funds for questionable projects implemented by the City of Miami Beach. HACMB's records indicated that the city may have pressured it to execute contracts for the projects. However, the HACMB was responsible for ensuring proper use of the Section 8 funds. Specifically, the HACMB funded the projects without adequate consideration of an opinion from its attorney that some of the projects did not represent an allowed use of funds and that other projects required attention to certain details during implementation to ensure their eligibility. As a result, the HACMB paid the city $795,178 for three projects which were for activities the city should have provided and paid from local tax revenues. The expenditures occurred because the HACMB's Board of Commissioners and Executive Director mismanaged Section 8 resources. Housing authorities may use administrative fee reserves for other housing purposes permitted by state and local law (24 CFR, 982.155 (b)(1)). Florida's Housing Statute states that no housing authority shall construct or operate any housing project as a source of revenue to the city (Section 421.09). Oril!in of Fundinl! Arranl!ement: On June 11,1992, HACMB and city officials met and agreed to a mission statement designed to utilize portions of the HACMB's large Section 8 reserves for community development activities. The mission statement provided that the projects must meet HUD's criteria and receive annual HUD approval. On June 24, 1992, the HACMB's Board adopted a resolution that approved the mission statement. The HACMB's attorney prepared a memorandum, dated October 13, 1992, which indicated that the city used some pressure to persuade the HACMB to enter into contracts for project services. The memorandum, addressed to the Executive Director and the HACMB's Board, commented that: " ...A perceived threat that the city administration will ''take over" the Housing Authority if it does not acquiesce is not sufficient consideration for the Authority to contractually obligate itself to relinquish control over a substantial portion of its cash reserves." During the October 13, 1992, HACMB Board meeting, a city official stated that the city never threatened to take over the housing authority. Funded Activities - On November 10, 1992, HACMB' s Board of commissioners voted to fund projects for police, recreation, child-care, and code enforcement to be implemented by the city. HACMB's attorney attended the Board meeting and voiced his objections and reservations to the proposed projects in an oral presentation before the Board and in a memorandum, also dated November 10, addressed to the HACMB Board Chairman, Executive Director, and Board. The memorandum prjvided-lt-Iegar"OpiniNr--._- which opposed funding for the police and code enforcement r' ts ovi eQ a.._ conditional approval of the recreation and child care projects. ueR ~~ 1 8 approved the police and code enforcement projects despite the valid concerns raised by the attorney. Also, the HACMB did not heed the attorney's advice to ensure that the recreation program was implemented to benefit the targeted group of residents. The HACMB heeded the attorney's advice in the way it implemented the child care project. The contracts between the HACMB and city contained provisions that required the city to reimburse the HACMB should HUD take exception to contract costs. Proiect Implementation - From inception through February 2000, the HACMB expended $938,619 of its Section 8 administrative fee reserves to fund projects with the city through inter-local agreements. We used judgmental tests during our review of HACMB and city cost records and performance measures associated with the projects. The costs incurred for the child-care program were supported and reasonable. However, we identified questions concerning the police, recreation, and code enforcement activities which paralleled the concerns expressed by HACMB's attorney prior to the projects' initial approval for funding: Activity Police Protection Recreation Child-care Code Enforcement Total Costs $425,842 335,736 143,441 33.600 Allowed Ouestioned $425,842 335, 736 $143,441 33.600 Total $938.619 $143.441 $795.178 The HACMB inappropriately paid the city $795,178 for projects that the city should have funded with local tax revenues. We identified the following issues that caused us to question the amounts the HACMB paid to the city for police protection, recreation, and code enforcement projects: Police protection - The HACMB funded the project over the objections of its attorney who advised the HACMB that the activity did not represent an allowed use of funds. The attorney's November 10,1992, memorandum stated: This proposal, for the HACMB to fund two new CMB [City of Miami Beach] police officers, in my opinion, does not set forth a permitted or lawful use of housing assistance funds. If we had massive, self-contained housing projects in Miami Beach, requiring special police services on a regular basis, the Housing Authority might be permitted to purchase police services from the city. It should be noted that the Miami Beach Housing Authority already employs private security guards for the protection of its public housing tenants. DRAFT 9 The Board minutes showed that HACMB commissioners voted to approve the project despite the attorney's objections. The HACMB continued to fund the project from November 1992 through the period covered by our audit at a cost of $425,842. We examined 100 percent of the costs. The agreements called for police to patrol areas at and in the vicinity of where Section 8 tenants lived and to provide other services related to investigations and community relations. The services were of the type normally expected from a police force as routine services paid from local tax revenues. The HACMB owned only two large projects (200 units each) joined by a common walkway for which it employed a fIrm to provide security. The 2,700 privately owned Section 8 units were not in concentrated. areas, but were scattered throughout the Miami Beach area. On September 9, 1992, the assistant city manager informed the HACMB's Board that the police department had divided the city into 26 sectors. He stated that an offIcer is responsible for patrolling each sector and identifying areas within the sector they are going to pay more attention to. This comment further indicated that the city's normal police patrol covered or should have covered the areas and vicinity where Section 8 tenants lived in privately owned housing. We agree with the attorney's determination that the activit)[ did not represent an allowable use of funds. Recreation - The inter-local agreements stipulated or implied that the recreation program would provide top priority to tenants of Section 8 units and other subsidized housing. The agreements did not limit the level of assistance the program may provide to individuals who were not in the target group. The later agreements stated that the city would continue to provide all transportation and related services for participants. The HACMB paid the city $335,736 for this acttvlty which we considered questionable. We examined costs totaling $254,542 (76 percent) and determined that the payments amounted to an operating subsidy for city parks. To illustrate, the city claimed reimbursement for general park operating expenditures such as salaries, bus services, instructor fees, trophies, baseball supplies/uniforms, picnic supplies, recreational supplies, etc. The costs appeared to represent general local government parks and recreation costs. Some of the payments were not supported by vendor invoices. We also noted that the city requested and received reimbursement for $12,439 incurred for bus services. The inter-local agreement stipulated that the city would provide all transportation and related services for participants in the program. 10 to RA FT Furthermore, the HACMB and city did not maintain records to demonstrate whether any of the $335,736 benefited the target group. The HACMB did not heed the advice of its legal counsel during its implementation of the recreation activity to employ strict controls to ensure that the program served those for whom it was intended. The attorney stressed that the HACMB funds must be utilized for the benefit of qualified housing assistance recipients. We questioned the full $335,736 paid for this project because HACMB lacked any documentation that the activity provided any measurable benefit. Code enforcement - The costs paid for this activity appeared to be a supplement to the city's code enforcement division and it was not a reasonable and necessary HACMB expense. We examined 100 percent of the $33,600 the HACMB paid the city for the code enforcement project. The agreement provided that the activity was for one city code enforcement officer to annually inspect 1,000 Section 8 units or units that affect those living in subsidized housing. The documentation provided to support the payments did not show how many units the city inspected. On November 10, 1992, the day the Board voted to approve the project, HACMB's attorney advised the Board of Commissioners and Executive Director that the code enforcement project did not meet the legal requirements for funding because the HACMB employed its own inspectors. The Board did not heed the attorney's advice and approved funding for the project. We agreed with the attorney's rationale and assessment that the project did not meet the requirements for HACMB funding. The activity appeared to be a supplement to the city's inspection division for work that it was required to do anyway. For instance, during the November 10 Board meeting, the assistant city manager stated that the city was behind on conducting preventive inspections and that the HACMB funding would close the gap. HACMB's inspections supervisor stated he did not see a benefit to paying the city for code enforcement. The HACMB funded the project for only one year (1992/93) at a cost of$33,600. Inadequate Monitorin2 - The HACMB basically paid what the city billed for inter-local activities without adequately monitoring project costs and services. For instance: · Services were not provided at contract levels. The HACMB did not establish adequate general ledger expense accounts to track costs paid under the inter-local agreements. Until November 1999, the HACMB charged contract disbursements direc;:tly to the 2826 reserve account. The only payment charged to an expense account was check number 25303, dated November 23, 1999, for $163,303.15. The payment was charged to one account, however, the check included $96,106 for recreation, $63,754 for police protection, and $9,470 for child care. The HACMB had not established accounts to track costs .for each separate activity. IDRAFTI 11 Separate accounts were needed to assure that the city provided services at the contracted level and price. To illustrate, from inception of the inter-local agreements through February 2000, the HACMB paid the city $58,585 in excess of the contract amount for police services (costs questioned above) and $129,559 less than the contract amount for child-care services. HACMB and city officials were not aware of these conditions until we brought them to their attention. The HACMB should have been aware of contract payment trends and it should have initiated timely actions to prevent the overpayment and to assure that the city provided the contracted level of child-care services. . The HACMB disbursed funds in advance of its need to pay for contract activities. In March 1993, the HACMB advanced $245,667 to the joint benefit fund used to pay the city for inter-local project activities. HACMB and city officials had to sign checks issued from the benefit account. Large portions of the $245,667 remained in the account for over a year without being utilized. For instance, following the payment, the account balance remained at over $200,000 for seven months and over $100,000 for an additional four months. We noted other similar periods of delayed spending. As of February 29, 2000, the account had a balance of $46,562. Interest earned on the funds was charged back to the benefit account. The above issues resulted from mismanagement of fmancial affairs by the HACMB's Board of Commissioners and Executive Directors. The former HACMB attorney put the Board on notice prior to their approval of the projects that the police and code enforcement activities were not allowable and that the recreation activity required special considerations to ensure its eligibility. The Board virtually ignored the attorney's advice and approved the projects. FurthermorJ:, the Board did not seek HUD approval for use of the funds. The HACMB's September 9, 1992 Board minutes showed that HUD had reminded the HACMB of its responsibility to ensure that each activity conform with the statutes, regulations, and the obligations of the housing commission. HUD's Concerns - On June 22, 2000, HUD issued a report stemming from its February review of HACMB's operations which contained an observation concerning the inter- local agreement. HUD questioned the reasonableness of the cost and directed the HACMB to cancel the contracts with the city and not to award future contracts of this type to the city. Auditee Comments 12 to RA FTI Recom mendations Finding 2 Housin!! and Social Services Not Provided The HACMB wasted over $2 million in a failed effort to provide housing and social services due to inadequate planning and management of human and financial resources. The HACMB had not developed final plans to fund, construct, and operate the project. The HACMB spent $2 million for the planned project but still had not broken ground to construct the building needed to provide the housing and space for the social services. The project had been delayed for over five years and the HACMB had lost or was at risk of losing almost all of the $5.8 million originally committed to fund the project. Furthermore, the city was developing plans that may prevent the HACMB from constructing the center on the planned site. We question whether the HACMB will recover any significant portion of the $2 million wasted on the failed project. HACMB's failure to complete the project deprived the city's low income community of the needed housing and social services. HUD's Waiver to Allow for the Proiect - In November 1994, HACMB requested HUD's approval to refund the bonds issued in 1978 to finance Rebecca Towers North, a 200 unit Section 8 new construction project. The 1978 bonds were issued pursuant to 24 CFR 811 which prohibited the issuance of obligations to refund the bonds. However, the HACMB's request for waiver stated that they wanted to refund the bonds to generate over $2 million to finance the construction of a single parents and family housing resource center. The project would provide shelter for battered women and children. On April 17, 1995, HUD approved the waiver request on condition that the funds be expended to provide housing for the purposes described. Proiect Fundin!! and Delav Construction - On April 26, 1995, the HACMB refunded the bonds which provided $2.3 million to fund the center. At the time of our review, five.. years 'had passed since the bond refund. The HACMB still had not constructed the center nor had it developed final plans to construct and operate the center. In June 1999, the HACMB's Board met to discuss the failed project. The Board minutes showed the project had not succeeded because of mismanagement. During the meeting various members of the Board and/or the Executive Director expressed concerns such as: . The project did not succeed due to mismanagement. . The HACMB returned $525,000 in state funding for the project. . The project's cost estimates were incomplete. . HACMB does not have the money nor plans to construct the project. . Despite controversy from the start, the Board always voted to move forward with the project. We agree with the Board's belated but accurate assessment as to why the project was not completed. However, the Board and HACMB had a responsibility to assure proper management of staff and financial resources to complete the project. The poor planning W RAFT 13 and management prevented the HACMB from providing the needed housing and social services to residents of the city's low income community. For instance, the HACMB's June 1994 application to the state for $525,000 to assist with financing the project stated that the target population was homeless women and children, battered women and children who become homeless when removed from abusive situations, and families on HACMB'a waiting list. The application stated that the HACMB identified the need for the housing and social services through a needs assessment performed by a university. HACMB's mismanagement of staff and financial resources associated with the project resulted in its: . Loss or risk of losing almost all of the $5.8 million initially committed to the project. . Expenditures of over $2 million for site acquisition; site improvements; and predevelopment costs which may have been wasted. . Lack of a fmal project design and fmancial plan needed to complete and to operate the project. Fundin!! Lost or at Risk of Bein!! Lost - The HACMB obtained the following funding commitments for the project which it had lost or was at risk of losing: Sources of Funds Private loan State loan State grant Federal Home loan HOME loan Bond proceeds Other - HACMB Equity Per 1994 State Loan Application $2,039,000 500,000 25,000 o 380,000 2,287,313 559.200 Per 1995 HOME Al!feement $1,598,943 o o 500,000 760,000 2,300,000 1.500.000 Total $5.790.513 $6.658.943 The HACMB lost or was at risk of losing all except the HACMB equity portion of funding due to project delays and redesign. For instance: . HACMB's latest redesign of the project resulted in a facility which cannot take on any of the private debt anticipated by the above projections. In October 1996, HACMB reduced the number of proposed housing units in the project from 52 to 40. The HACMB stated that they made the revision due to .c.9st~.,.co.lD.J1lunity'_'_'____'1 pressure, and special needs that arose. HACMB's estimated ca~h flows ,.for, the.,40 .,'~ .""~ - ~ Ur\rlr I 14 pressure, and special needs that arose. HACMB's estimated cash flows for the 40 unit project, which excluded debt service, showed it would operate at a negative cash flow. Thus, the project could not take on any of the private debt anticipated by the initial plans to construct 52 housing units. In addition, HACMB's board chairman and board minutes from the June 1999 board meeting indicated that even the 1994 and 1995 estimates were flawed because they did not anticipate certain construction (e.g., water and sewer) and operating costs for the center. . The HACMB returned the $525,000 state funding which it applied for and needed to assist with construction of the project. . The HACMB did not meet the HOME agreement requirement that the project be completed and ready for occupancy by December 1997 or no longer than 60 days thereafter. On June 9, 2000, the City of Miami Beach requested confIrmation of HACMB's plans and time frame regarding whether it would pursue the project or an alternative project. The City made this request in response to HOD's identifying the project as "slow moving" and an effort to expedite the expenditure of the HOME funds. On August 8, 2000, the HACMB wrote the City and informed them that they were committed to constructing the project using the HOME funds. . The HACMB did not meet the two-year deadline required by bond certifIcations to complete the project. This may result in the loss of the remaining $2 million bond proceeds held by the trustee (Section 3(d) of the Non-Arbitrage CertifIcation). EXDenditures - The HACMB had spent over $2 million but still had "hot broken ground to construct the project. The expenditures included the following amounts recorded in HACMB's general ledger, which we did not audit, and for bond issue costs: Section 8 Descriotion Total Bonds Reserves Bond issue costs $203,175 $203,175 Land acquisition 980,000 $ 980,000 Architectural services 340,322 340,322 Seawall Construction 183,251 183,251 City fees and permits 209,570 209,570 Other 125.018 125.018 Total $2.041.336 $726.748 $1.314.588 15 j)ratt years of HACMB mismanagement and indecisiveness concerning the project design and approach. Also, the fees paid to the City of Miami Beach ($209,570) were excessive considering the project was not constructed. The project was a joint venture between the city and the HACMB pursuant to an affordable housing joint venture agreement. The HACMB should seek relief by recovery of fees paid to the city in anticipation of construction that never occurred. Incomplete Plans to Construct and to Operate the Proiect - At the time of our review, the HACMB and its Board had not developed plans and financial arrangements needed to complete and operate the project. The HACMB's board had discussed the possibility of a revised project design and use of an alternative site if they proceeded with the project. The Board Chairman and others also expressed concern that the existing site has an irregular shape for such a project and was not safe for children because one side of the property line is bordered by a canal. These concerns should have been considered prior to the site acquisition. In 1999, the HACMB engaged a consultant to prepare an assessment of the project's status. The consultant reported an estimated cost of $9,662,145 to construct the project. The consultant also projected annual operating deficits of over $100,000. -The consultant further stated that HACMB's prior cost estimates for the project omitted certain capital costs valued at approximately $1 million (e.g., water and sewer). The HACMB paid $980,000 for the site. HACMB officials stated that the property was appraised for $2.1 million. However, the city recently informed the HACMB that it was considering a road construction project that may impact the site planned for the center. The city's plans may prevent the HACMB from constructing the project on the planned site. Considering this development, we question whether the HACMB will be able to recover the $2 million it spent on the project. Auditee Comments Recommendations 16 ~ RA FT\ Finding 3 Mismanal!:ement of Section 8 Prol!:ram The HACMB did not adhere to HUD requirements designed to assure the reasonableness of Section 8 rents. The HACMB also did not timely execute new leases for tenants who moved from one assisted unit to another, and pay tenants for the amounts by which their utility allowances exceeded the family's contribution for rent. As a result, there was inadequate assurance that HUD subsidized reasonable Section 8 rents and that tenants received the full benefit of their utility allowances. We also noted some cases where the HACMB and owners provided false representations concerning rent reasonableness. These conditions caused HUD to pay $9,267 in excessive subsidy. The noncompliance occurred because HACMB employees failed to carry out the duties they were employed and entrusted to perform. Findinl!:s from Past Reviews - Reviews conducted by HUD and a consultant commissioned by the HACMB, disclosed serious problems with the HACMB's administration of its Section 8 programs. For instance, HUD's June 22, 2000, review reported violations of requirements for occupancy (including waiting lists and re- certifications); inspections, abatements, utility allowances, rent comparabili!X, and the approval of rent increases. Due to the recent reviews, we primarily limited our examination to the determination of rent amounts and utility allowances. We observed problems similar to those noted in the HUD review for inadequate approval of rent increases. HUD's review adequately addressed the problem and recommended appropriate corrective action. However, we observed the following additional matters: Excessive rents charged for assisted units Leases not timely executed when tenants changed units Excess utility allowance not paid to tenants Excessive Rents Charl!:ed for Assisted Units - The housing authority (HA) may not approve a lease and any rent increase until it determines that the rent to owner is reasonable in comparison to rent for other comparable unassisted units. By accepting each monthly housing assistance payment from the HA, the owner certifies that the rent to owner is not more than rent charged by the owner for comparable unassisted units in the premises. The owner must give the HA information requested on rents charged by the owner for other units in the premises or elsewhere (24 CFR 9982.503). We examined HACMB and owner records for rents charged at 11 projects. The projects contained 72 assisted and 91 unassisted units. The rents charged by three owners for seven assisted units (10 percent) exceeded the rents charged within the same projects for comparable unassisted units. The HACMB did not obtain and evaluate the rents owners charged for unassisted units located at the same properties. 17 [5 R Art The Housing Assistance Coordinator stated that they generally provided landlords whatever rents they requested as long as the rents did not exceed the published fair market rent for the unit size. The coordinator further stated they justified the . owners' rent by selecting as comparables other assisted units that rented for the same amount requested by the owner. The violations resulted in false representation by HACMB officials and the affected owners concerning the determination of rents for the seven units. The three owners did not maintain all the leases and rent rolls we needed to calculate the dollar impact of the violations during the audit period. However, from the available records, we calculated excessive subsidies of $6,667. The matter is significant considering that the HACMB administered over ft7f)Q J,ection 8 units in an environment of disregard for HUD's requirements for det~di8g rent reasonableness. The owners provided various explanations to justify why they charged more for assisted units than they did for the unassisted units located in the same projects. However, the HACMB did not determine what the owners charged for unassisted units. Thus, they conducted no follow-up concerning the differences. " In July 1999, the HACMB designated an employee to conduct rent reasonableness determinations for all initial leases. We noted improved performance for rent reasonableness determinations for initial leases following this action. However, the change _only affected initial leases and did not include rent reasonableness determinations for lease renewals. The HACMB continued to violate HUD's requirements for rent reasonableness determinations for lease renewals. Leases Not Timelv Executed when Tenants Chane:ed Units - The HAP Contract only applies to the family and the contract unit. If the family moves out of the unit, the HAP contract terminates automatically (Part B of HAP Contract, Sections 4 and 6). Since both the HAP contract and the lease are tied to the specific unit address, a new contract and lease should be executed when the tenant moves from the unit. The HACMB- did not require and execute new leases for two tenants who moved from one assisted unit to another (same owner) prior to the expiration of their leases on the prior units. The HACMB allowed the owners to continue charging rents stipulated in the old leases at the new locations until the expiration dates for the old leases. This was significant because the contract rent for the old units exceeded the applicable fair market rent at the time of the moves. The HACMB's failure to execute new leases and appropriately establish initial gross rent (at or below fair market rent) resulted in excessive subsidy payments of $2,600. The Housing Assistance Coordinator said they stopped this practice in mid 1999 based on clarification from HUD. We reviewed documentation that supported HACMB's corrective action. - '^ -".-- -- -. '" __ _. ______ DRAFT 18 Utility Pavments Not Made to Tenants Utility reimbursement, the amount by which any utility allowance exceeds the tenant's portion ofrent, shall be paid to the family (24 CFR ~5.615). Prior to January 2000, the HACMB did not pay tenants the amounts due when their utility allowances exceeded their required contribution for rent. The HACMB should have written checks to those tenants whose utility allowance exceeded their portion of rent. We could not determine the amount of utility reimbursements due tenants because the HACMB did not keep records needed to make that determination. Utility reimbursements for January to June 2000 amounted to $3,565. The above matters occurred due to mismanagement associated with HACMB staff not performing the duties for which they were employed and entrusted to perform. For instance, the Housing Assistance Coordinator stated that no one showed her and other staff what to do to meet HUD requirements and that the HACMB administration did not provide needed training. The HUD regulations and handbooks are readily available to housing authorities from HUD. At a minimum, the Housing Assistance Coordinator was responsible for ensuring that she and her staff had and were aware of the basic requirements associated with the violations discussed in this fmding. By the time we completed our review, the HACMB had initiated some changes designed to improve its administration of Section 8 programs. HOD placed the HACMB's Section 8 program on probation for one year and required the HACMB to contract out administration of the Section 8 program. We observed that the HACMB assigned another employee to oversee the Section 8 leasing and inspection departments and had hired a consultant to assist in the management and the training of Section 8 staff. The new Section 8 manager and consultant stated that their priority will be to implement procedures to address HUD's findings and to bring the Section 8 department into compliance with HOD regulations. Auditee Comments Recommendations 19 lDRA f/ f) l- /4c/;<.oll . ;,A,r{ '!7fMt fllfi5 . [T i I Finding 4 Need to Improve Procurement Administration The HACMB had not implemented corrective actions recommended by past reviewers of its operations to comply with procurement requirements. For instance, the HACMB subsequently acquired legal services and small purchases without adequate assurance that they obtained the most advantageous cost from the most qualified sources. These conditions occurred because the HACMB and its Board mismanaged the administration of procurements. Inadequate Attention to Past Procurement Findinl!s - The HACMB had not implemented adequate steps to correct weaknesses in its administration of procurements identified by its independent auditor and HOD: . Independent Auditor's Report - The independent auditor's report for the fiscal year ended June 30, 1998 (report dated January 26, 1999) stated that the HACMB did not properly advertise and seek competition for consulting services. The report stated that the HACMB split the work into two contracts to avoid having to advertise and seek competitive bids. . HUD Monitoring Review - In February 2000, HOD reviewed the HACMB's operations and determined that it had violated procurement requirements in its purchase of accounting and program software; audit services; consulting services, and air conditioners. At least one of these procurements occurred after the HACMB received its independent auditor's report that notified it of the need to follow procurement requirements. For instance, HOD reviewed a request for proposal dated March 1999 to purchase accounting and computer software. HOD determined that the HACMB did not follow required procedures for competition. We performed additional tests to determine whether the HACMB initiated improvements in its procurement practices following the above reviews. We observed that on March 4, 1999, the Board approved HACMB's revised procurement policy. However, we determined that the HACMB had not implemented effective measures to follow the policy and HOD requirements for legal services and small purchases. Procurement of Lel!al Services - All procurement transactions will be conducted in a manner providing full and open competition (24 CFR 85.36(c)(1)). The HACMB's procurement policy required use of the competitive proposal method of procurement to acquire legal services (Section D). We reviewed HACMB's in-process procurement of legal services initiated by a board resolution passed on March 14,2000, and identified numerous problems with the procurement: 20 -OR-A{Yj -;f . The HACMB board authorized its general counsel to handle the procurement versus the HACMB's administrative staff. The attorney prepared and mailed the RFPs; advertised for bids; obtained and evaluated bids, and recommended contractor selection. The attorney had exclusive control over the procurement process which should have been handled by HACMB staff. · The attorney did not obtain proper competition to allow award of the contracts. The attorney stated that he received three bids, one for each of three different types of legal services, and proposed to award a contract to each firm. We discussed our concerns with HACMB's Board chairman and acting Executive Director on April 27, 2000, and with HOD on May 4, 2000. On May 8, 2000, HOD instructed the HACMB not to execute either of the contracts until HUD conducted a pre-award review of the proposed procurements. . At the May 9, 2000, board meeting, the board voted to award two of the three proposed legal service contracts despite our concerns. We notified HUD of this action and on May 24,2000, HUD.wrote another letter to the HACMB which stated that if they awarded the contracts despite HUD's expressed concerns, then no federal funds may be used to pay for the services. The HACMB decided to re-do the procurement only after it received this notice from HUD. · The HACMB halted the procurement and subsequent to our review prepared another RFP and re-advertised for the legal services. We did not review the subsequent procurement. HACMB received bids from eight firms in response to the RFP from which the Board voted to approve four legal service contracts. No Authority staff, including the interim ED, reviewed the proposals. We also observed several procurement concerns related to the HACMB's purchase of other legal' services. For example, the HACMB contracted with its current legal counsel without following proper competitive procurement procedures. The HACMB also made payments to two law firms which the HACMB hired, based on the recommendation of its legal counsel, without following competitive requirements. Between July 1999 and May 2000, the HACMB paid the firms $44,690 which was charged in part to public housing and in part to Section 8. One firm was among the three mentioned above which the attorney proposed awarding a recent contract for labor services without proper competition. Small Purchase Procedures Not Followed - When small purchase procedures are used, an adequate number of price or rate quotations shall be obtained from an adequate number of qualified sources (24 CFR 85.36(d)(1)). The Authority's procurement policy required price quotes from no less than ffers for DRAF-r 21 purchases between $1,000 and $10,000. Purchases greater than $10,000 required competitive procurement methods (Section B). We examined small purchases charged to the HACMB's low income housing program (Rebecca Towers South) for the period December 1999 through May 2000. Through April 2000, we noted numerous payments for small purchases which the HACMB did not obtain or document bids or price quotes. The costs included $22,000 for office and communication supplies and services; ADP and accounting services and equipment; insurance; landscaping; repairs and maintenance; trash removal; consulting costs, and cleaning and laundry. We noted sporadic instances where the HACMB did obtain bids or price quotes but for the most part they did not. Starting in May 2000, the HACMB demonstrated efforts to correct its past inconsistent compliance with requirements to obtain and to document bids or price quotes for small purchases. We tested six small purchases during the month. The HACMB properly obtained and documented bids or price quotes for each purchase. We attributed these conditions to the HACMB's failure to properly administer the procurement of goods and services after it was alerted to the need for corrective actions. The board and the HACMB had a duty and responsibility to assure compliance with procurement requirements, especially considering past findings related to this issue. The Board's lack of consideration for requirements was demonstrated by its direct involvement in the most recent procurement of legal services and its reluctance to assure compliance with competitive procurement procedures. Auditee Comments Recommendations ----- ---- ----_..~_.--- -~- -~. 22 DF{AFT Management Controls In planning and performing our audit, we considered the management controls of the Miami Beach Housing Authority only to determine our auditing procedures and not to provide assurance on these controls. Management controls include the plan of organization, methods and procedures adopted by management to ensure that its goals are met. Management controls include the processes for planning, organizing, directing, and controlling program operations. They also include the systems for measuring, reporting and monitoring program performance. We determined that the controls most relevant to our audit objectives pertained to the following: . Management philosophy and operating style; . Procedures and practices for determining and assessing the reasonableness of Section 8 rents and utility allowances; and . Procedures and practices for procurement and general disbursements. We assessed these controls by obtaining an understanding of the HACMB's procedures and HUD requirements. However, based on past review of HACMB's operations by consultants, IPAs, and HUD, the HACMB controls and procedures relevant to our audit objectives were not reliable and we placed no .reliance on the controls in designing our audit tests. A significant weakness exists if controls do not give reasonable assurance that goals and objectives are met; resource use is consistent with laws, regulations and policies; resources are safeguarded against waste, loss, and misuse; and that reliable data are obtained, maintained, and fairly disclosed in reports. Based on our review, significant weaknesses existed in each of the management controls considered relevant to our audit objectives. The specific weaknesses are discussed in the findings. ORA FTl , 23 Follow-Up on Prior Audits The OlG issued an audit report on June 7, 1991, regarding the HACMB's Section 8 Project-Based Certificate Assistance Program. The audit contained three findings which have since been resolved. Independent Public Accountants (IPA's) performed single audits of HACMB's operations for the fiscal years ended June 30, 1998, and 1999 that contained findings on issues that were relevant to our audit objectives. The IP A report for the fiscal year ended June 30, 1998, contained a fmding on procurement that involved issues similar to those presented in finding 4 of this report. The IP A report for the fiscal year ended June 30, 1999, contained fmdings related to purchasing and utility allowances which involved the type of concerns presented in fmdings 3 and 4 of this report. HACMB had not developed a written action plan with target dates to address all the problems identified by the IP A reports. ,- 24 DRAFT 9nJOO DRAFT - Subject to Cbange OIG's Proposed Recommendations We recommend that you require the HACMB to: IA Recover from the City the $795,178 paid for police protection, recreation and code enforcement activities. 1 B Establish proper general ledger accounts and properly monitor expenditures for future activities funded with Section 8 reserves. See recommendations 3A and 3D which provides for additional actions that apply to all Section 8 mismanagement issues discussed in this finding and those presented in findings 2 and 3. *******.*.**************** We recommend that you require the HACMB to: 2A Provide evidence that it can and will complete construction of the center within a reasonable time, as determined by your office, on the current or at an alternate site. rfthe HACMHB cannot provide satisfactory plans to construct the project within the time frame determined by your office, then you should require it to: 2B Immediately sell the site purchased for the center for its fair market value. The HACMB should use the proceeds to reimburse Section 8 and the bond construction funds in proportion to the share of costs paid from each fund. 2C Recover from the City the $209,570 paid to the City from Section 8 reserves for fees associated with the failed joint venture project. We also recommend that you: 2D Decide the disposition of the remaining bond funds (including those recovered in response to recommendation 2A) obtained or accumulated (e.g., interest earned) for construction of the center. See recommendations 3A and 3D which provides for additional actions that apply to all Section 8 mismanagement issues discussed in this finding and those presented in findings 1 and 3. *********************** 1 ~ 9nJOO DRAFf - Subject to Change OIG's Proposed Recommendations We recommend that you require the HACMB to: 3A Restrict the use of all Section 8 administrative fee reserve until you detennine and provide written notice to the HACMB that it has substantially resolved the systemic violation of Section 8 requirements. The issues requiring resolution includes the questioned Section 8 costs mentioned in findings 1 and 2. We make this recommendation pursuant to the provisions of24 CFR 982.156 (b)(3)). Until your office provides written notice to remove this restriction, the HACMB should provide you with written notice on planned uses of Section 8 reserves and obtain your written approval before obligating and spending any of its Section 8 reserves. 3B Procure the services of an independent contractor to calculate the amount of utility reimbursements due tenants for past periods and to make the required payments due tenants. Your office should instruct the HACMB as to the calculation period for inclusion in the request for proposal used to procure the contract. 3C Reimburse HUD $9,267 for the excess HAP payments disbursed to Section 8 owners. We also recommend that if the HACMB has not significantly resolved its Section 8 administrative problems within one year of the issuance of this report ( including the Section 8 cost issues discussed in findings 1 and 2) that you: 3D Declare a breach of responsibility under the Consolidate Annual Contribution Contracts for Section 8 programs. You should also identify and refer the responsible officials to HUD's enforcement center for consideration of administrative sanction. ********************** We recommend that you: 4A Review and determine if the HACMB completed the procurement oflegal services pursuant to requirements. If the procurement was not handled properly, you should prohibit the HACMB from charging any of the costs to its Public Housing program. 4B Provide an immediate written notice to the HACMB that due to the repeated violations of procurement requirements your office will seek to identify individuals responsible for future violations of requirements and hold them accountable for their actions. This may include but may not be limited to referring such individuals to HUD's Enforcement Center for possible administrative sanctions (e.g., limited denial of participation and or debarment)). 2 ~ o o w ~ is :J <( I .. 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