BACKGROUND:
In the early Spring of 2009 a now laid-off Community Revitalization Department employee provided me with a copy of the above-captioned 30-page HOME Program Wellness Assessment. Copies were then given to my Cincinnati attorney, a recent unsuccessful City Council candidate and a prominent local real estate professional who has held numerous offices with the Middletown Board of REALTORS. I haven't revealed this document until now as it seems that I don't have the necessary resources to pursue legal action against the City of Middletown.
QUESTION:
As you read this, surely it couldn't be possible that a certain senior City staff member may be sheltering(?) someone else at One Donham Plaza insofar as the alleged waste and mismanagement of pre-2007 HUD funds are concerned?
HOME WELLNESS ASSESSMENT OVERVIEW (PART ONE):
In early 2007 ICF International, a major training and technical assistance provider from Fairfax, Virginia, was asked by the HUD Columbus Field Office to complete a Wellness Assessment of the Butler County Ohio's Home Investment Partnerships (HOME) Program. Butler County is a consortium under the HOME Program and with the City of Middletown, Ohio as a Consortium member. Each member receives approximately $400,000 per year.
NOTE: The HUD Columbus Field Office was not provided with a copy of the full report. The intent of the Wellness Assessment was to provide Butler County and the City of Middletown with technical assistance to ensure that they were: 1) administering grants according to HUD rules and regulations; and, 2) to enable the Consortium members to make necessary corrective actions to avoid future HUD monitoring findings and concerns.
ICF International staff spent three days in Hamilton and met with Butler County staff only. They did speak by phone with one of my two Neighborhood Improvement Advisors for the City of Middletown. The other, Skip Batten, provided ICF with copies of Owner-Occupied Housing Rehabilitation Program contract documents, etc.
RISK AREAS:
General Administration
A) ICF discovered that several pre-2007 program activities were implemented in non-compliance with HOME Program rules and regulations.
B) They also found that the Consortium members did not appear to have adequate staff capacity to appropriately administer the HOME Program funds that are received annually.
Inadequate Income Eligibility Reviews
Owner-Occupied Housing Rehabilitation Program pre-2007 files obtained from the City of Middletown did not contain verification of assets such as checking accounts plus the source documentation in files provided was outdated. It was unclear if income was reverified within six months of the provision of financial/technical assistance because the prior documentation was out of date.
Risk Mitigation
ICF recommended that the Consortium members adopt an income eligibility certification form for all HOME Program assisted activities. For the City of Middletown, part of the risk stems from the length of time of the application and the start of rehabilitation work. If the City of Middletown was unable to process Owner-Occupied Housing Rehabilitation Program applications more quickly, then they should use a pre-application to gauge initial eligibility followed by a complete application with up-to-date income verification closer to the time of assistance.
To address these deficiencies I asked Debbi Fish (now laid-off) to work closely with other Community Development Division staff in processing Owner-Occupied Housing Rehabilitation Program applications. I also approved her to attend HUD training on Income Eligibility Certification to put an end to the problems of the past.
TO BE CONTINUED