We completed a review of the Buffalo Municipal Housing Authority’s legal and police service expenses in response to a hotline complaint.  The complainant alleged that Authority officials paid outside legal counsel for work that should have been done by its own legal staff and paid for police services below the baseline level of services that should have been provided under a cooperation agreement with the City of Buffalo.

The allegation in the hotline complaint pertaining to outside legal expenses charged by the Authority to its Federal programs had merit.  Authority officials made payments for outside legal services without documenting that these services could not be performed by the Authority’s internal general counsel and without ensuring full and open competition.  While the complaint that Authority officials paid for police services already provided under a cooperation agreement is without merit, Authority officials did not charge police service costs to the Authority’s asset management projects in an equitable manner in relation to the services provided.

We recommend that the Director of the U.S. Department of Housing and Urban Development’s Buffalo Office of Public Housing instruct Authority officials to (1) provide documentation to support the need for $211,216 paid for assistance from outside legal and that the services  were obtained through full and open competition; (2) establish procedures to ensure that they do not procure outside legal services that should be provided by Authority officials; (3) provide documentation showing that legal services for which $79,244 was paid were obtained through full and open competition; (4) strengthen procedures to ensure that legal services provided by outside firms are obtained in accordance with Federal procurement requirements;  and (5) establish procedures to ensure that a reasonable basis is used for allocating police contract costs to Authority projects.