DOI EXAMINATION FINDS COMPLIANCE AND GOVERNANCE RISKS AT 51 CITY-FUNDED NONPROFITS THAT OPERATE NYC HOMELESS SHELTERS AND FLAWED CITY OVERSIGHT OF DHS-FUNDED PROVIDERS —DOI issued 32 reforms to address system-wide vulnerabilities— Jocelyn E. Strauber, Commissioner of the New York City Department of Investigation (“DOI”), issued a Report today memorializing the key findings from DOI’s extensive examination of compliance risks at 51 nonprofit human service providers that operate many of the homeless shelters in New York City and of the City’s oversight of the shelter system. The Report includes DOI’s 32 recommendations for reform, intended to protect the billions of dollars that the City spends annually on shelter services from corruption, waste, fraud, and abuse. A copy of the Report follows this release and can be found here: https://www.nyc.gov/site/doi/newsroom/public-reports.page
DOI Commissioner Jocelyn E. Strauber said, “When it comes to protecting the vast taxpayer resources that City-funded nonprofits receive, prevention is key. City-funded nonprofit service providers pose unique compliance and governance risks, and comprehensive City oversight is the best way to stop corruption, fraud, and waste before it starts. This deep dive into the City-funded homeless service provider system builds on DOI’s extensive experience investigating nonprofit fraud, and our 2021 Report concerning City-funded nonprofits. Today’s Report provides ample evidence of the risks specific to nonprofits and shortcomings in City oversight and makes 32 recommendations to strengthen controls around this essential network. I thank the DOI team that has worked tirelessly on this investigation and the many City entities that provided assistance, including the staff from the City Department of Social Services who worked closely with DOI to support this examination.” The City, through the City Department of Social Services (“DSS”) and the City Department of Homeless Services (“DHS”), operates the largest homeless shelter system of any municipality in the United States. DHS-funded shelters currently support an average of over 86,000 people per night at a cost of approximately $4 billion annually in FY 2024, up from $2.7 billion annually in FY 2022, due in large part to the influx of asylum seekers over the past two years. (DOI did not review City-funded contracts involving services to the asylum seekers that were procured under emergency procedures for this Report. DOI has oversight of these expenditures through an integrity monitor that is supervised by and reports to DOI.)
The examination for this Report began in 2021, well before the influx of asylum seekers, although some of the providers DOI examined are providing asylum seeker services. DOI’s focus on this area was prompted in part by the investigation of Victor Rivera, the former CEO of nonprofit City service provider Bronx Parent Housing Network, who ultimately pled guilty to a federal bribery-and-kickback scheme involving that nonprofit. DOI investigators drew on their knowledge of financial and administrative vulnerabilities in City-funded nonprofit providers generally to examine individual shelter providers’ governance and compliance practices, and potential conflicts of interest and other potential misconduct during this examination of 51 nonprofit organizations operating shelters for DHS. DOI reviewed the 2 operations of these organizations and their responses to a detailed questionnaire; analyzed an array of materials including audit reports, financial ledgers, invoices, and disclosures to the City; and conducted dozens of interviews, including of certain providers’ senior executives. DOI also evaluated the oversight of these providers by the City, including by DHS and DSS. The provider practices and City oversight reflected in the Report dates from 2018 through the present, although the majority of DOI’s information-gathering was completed from 2022 through 2024.
DOI received approximately 70 responses to the questionnaire distributed to City-funded nonprofit organizations. To date, DOI has completed findings on 51 providers and issued related referral letters to DSS, each one summarizing DOI’s findings as to individual shelter providers and, in total, raising hundreds of governance and compliance concerns at these providers. The findings in these referrals already have caused some providers to make improvements to their policies and procedures. The Report makes 32 recommendations to the relevant City agencies to address system-wide vulnerabilities, strengthen controls with respect to providers to protect the substantial public funds providers receive, and enhance public trust. Aspects of this examination are still ongoing, and this Report is a summary of DOI’s major findings to date. This Report builds on the findings from the investigations DOI has conducted in recent years that have focused on the City’s nonprofit vendor spending and which have resulted in criminal charges, administrative findings, integrity monitorships, and recommendations to improve City oversight of these contracts and providers. Since 2018, DOI investigations have resulted in at least 25 arrests on charges involving fraud and corruption at City-funded nonprofits, including prosecutions related to homeless service providers. Since 2018, DOI also has issued more than a dozen administrative referrals to City agencies – in addition to the administrative referrals issued as part of this examination -- reporting findings of mismanagement, noncompliance, or other non-criminal misconduct at City-funded nonprofits. In 2021, DOI issued Report on Corruption Vulnerabilities in the City’s Oversight and Administration of Not-for-Profit Human Services, which identified gaps in the City’s general oversight of its contracts with nonprofit human service providers. Many of DOI’s prior findings and recommendations remain relevant to the findings of this Report, which focuses solely on the unique issues associated with the oversight of DHSfunded shelter providers.
This Report identifies a variety of compliance and governance risks at these providers, as well as in the City’s overall management of the shelter system. These risks vary in their severity and include: • Conflicts of interest affecting City money. DOI identified cases where insiders at the shelter provider had personal business interests involving the shelter through which they received payments outside their regular compensation. In some cases, shelter executives simultaneously held employment at a private entity, such as a security company, that was hired to provide services at City-funded shelters. • Poor Citywide controls over how City money is used for executive compensation. DOI identified multiple shelter executives who received more than $500,000 per year, and in some cases, more than $700,000 per year, from providers and related organizations. Executive compensation in these cases is funded either largely or in part through City funds. The City lacks sufficient rules concerning how much City money can be allocated to nonprofit executives’ salaries. • Nepotism, in violation of City contracts. DOI found shelter providers that have employed immediate family members of senior executives and board members, in apparent violation of their City contracts. For instance, one provider that is largely funded by the City employed its CEO’s children since at least 2007. This provider subsequently entered into a DOI-managed monitorship agreement. • Shelter providers failing to follow competitive bidding rules when procuring goods and services with public money. DOI found numerous cases where shelter providers did not comply with the City’s competitive bidding requirements or where it was unclear whether shelter providers conducted true competitive bidding processes. For example, this review identified multiple instances where shelter providers awarded multimillion-dollar building maintenance service contracts to companies affiliated with the buildings’ landlords.
DOI issued 32 recommendations to address the system-wide vulnerabilities noted in this Report. Included among the key recommendations are: ➢ DSS should appoint a Chief Vendor Compliance Officer to provide overall leadership for DSS and DHS’s compliance strategy with respect to nonprofit human service contracts, including contracts with shelter providers. ➢ Shelter providers should be required to regularly disclose additional information relevant to identifying compliance risks, including potential conflicts of interest for key persons. ➢ DSS and DHS should take steps to improve their oversight of shelter operators’ expenditures, including by immediately stopping payments for costs that are not accompanied by a proper description and ensuring that relevant agency staff receive regular financial compliance training. ➢ The City should update its electronic procurement and invoicing systems to better enable thirdparty oversight and centralize key documentation.
This Report also reiterates many of the 23 recommendations that DOI issued in its November 2021 Report on Corruption Vulnerabilities in the City’s Oversight and Administration of Not-for-Profit Human Services. While the City has implemented some reforms since the 2021 Report and is also undertaking some work that closely tracks DOI’s recommendations, many of the recommendations from 2021 have not been implemented at any substantial level. The 2021 Report recommended, among other things, that the City: Reform its conflict-of-interest disclosure system for the City’s human service providers. Develop more specific guidance to agencies on executive compensation and consider setting a cap or other parameters on City-funded executive compensation. Conduct more robust reviews of expenses that human service providers invoice to the City, including by reviewing larger samples of supporting documentation. New York City is currently making an unprecedented financial commitment to address homelessness. For that reason, it is more important than ever that it implement stronger risk management and compliance controls around this spending. Accepting and implementing the reforms set forth in this Report, as well as in DOI’s November 2021 Report, would be critical steps in this direction. DOI Commissioner Strauber thanks DSS Commissioner Molly Wasow Park and her staff, for their partnership on this examination and the Mayor’s Office of Contracts and Mayor’s Office of Risk Management and Compliance for their assistance. DOI also received support from two private firms with experience in investigations, audits, and compliance monitoring, who provided auditing and investigative resources with respect to certain provider reviews. At DOI, this examination was conducted by Deputy Inspector General/Special Counsel Daniel Kacinski and Confidential Investigator Rushelle Sharpe, with the assistance of Senior Investigative Auditor Olga Avram and Senior Investigative Attorney Alex Cane in DOI’s Office of the Inspector General for CityFunded Nonprofits. Data Analysts Anthony McDowald and Zachary Sayle and Director of Data Analytics Shyam Prasad in DOI’s Data Analytics Unit provided technical assistance. The examination was supervised 4 by Senior Inspector General Andrew Sein, Deputy Commissioner of Strategic Initiatives Christopher Ryan, and Deputy Commissioner/ Chief of Investigations Dominick Zarrella. https://www.nyc.gov/assets/doi/press-releases/2024/October/39DHSRptRelease10.17.2024.pdf
检查报告指出纽约市收容所系统存在一系列问题！
据侨报报道，市调查局（DOI）17日（周四）发布针对本市收容所系统检查报告，发现利益冲突、裙带主义以及包括多名主管年薪高达50万乃至70万的薪水超高等一系列问题，并提出多项改革意见。
该审查始于2021年，调查了51个非营利组织服务供应商。报告中指出的第一大问题为影响本市资金的利益冲突。 DOl确定了收容所服务供应商的内部人员有涉及收容所内部人士商业利益的情况，部分内部人士通过收容所获得常规补偿以外的付款。 部分收容所主管同时在受雇为收容所提供服务的私人实体工作。多名庇护所主管薪资超高，每年从供应商和相关组织获得超过50万到70万美元，其中主要或部分来自城市资金，因此本市缺乏足够规定以确定对于收容所高管工资的分配。
此外，DOI发现收容所系统存在违法城市合同的裙带主义，有服务供应商雇用了收容所主管和董事会成员的直系亲属。
而第三大问题为庇护所供应商在用公共资金采购商品和服务时未能遵守竞争性投标规则。
DOI局长史特劳勃(Jocelyn E.Strauber)表示，“市府资助的非营利服务提供商构成了独特的合规和治理风险，全面的城市监督是在腐败、欺诈和浪费开始之前阻止问题发生的最佳方式。今天的报告充分证明了非营利组织特有风险和城市监督缺陷，提出了32项建议以加强对这一重要系统的控制。” DOl发布了32条建议，以解决报告中指出的全系统漏洞。
包括市社会服务局（DSS）应任命一名首席供应商审核官，为DSS和国土安全部在非营利性利民服务合同方面的合规战略提供全面领导、应要求收容所提供者定期披露与识别合规风险相关的信息，包括关键人物的潜在利益冲突、DSS和市游民服务局（DHS）应采取措施改善对服务商支出的监督，包括立即停止支付模糊费用并确保相关工作人员定期接受财务合规培训、本市应更新其电子采购和发票系统，以更好地实现第三方监督并集中关键文件。
市府方面在对报告的回应中称，市府官员已同意了许多建议，并将制定一个书面计划，在90天内解决调查结果。
DOI EXAMINATION FINDS COMPLIANCE AND GOVERNANCE RISKS AT 51 CITY-FUNDED NONPROFITS THAT OPERATE NYC HOMELESS SHELTERS AND FLAWED CITY OVERSIGHT OF DHS-FUNDED PROVIDERS —DOI issued 32 reforms to address system-wide vulnerabilities—
Jocelyn E. Strauber, Commissioner of the New York City Department of Investigation (“DOI”), issued a Report today memorializing the key findings from DOI’s extensive examination of compliance risks at 51 nonprofit human service providers that operate many of the homeless shelters in New York City and of the City’s oversight of the shelter system. The Report includes DOI’s 32 recommendations for reform, intended to protect the billions of dollars that the City spends annually on shelter services from corruption, waste, fraud, and abuse. A copy of the Report follows this release and can be found here: https://www.nyc.gov/site/doi/newsroom/public-reports.page
DOI Commissioner Jocelyn E. Strauber said, “When it comes to protecting the vast taxpayer resources that City-funded nonprofits receive, prevention is key. City-funded nonprofit service providers pose unique compliance and governance risks, and comprehensive City oversight is the best way to stop corruption, fraud, and waste before it starts. This deep dive into the City-funded homeless service provider system builds on DOI’s extensive experience investigating nonprofit fraud, and our 2021 Report concerning City-funded nonprofits. Today’s Report provides ample evidence of the risks specific to nonprofits and shortcomings in City oversight and makes 32 recommendations to strengthen controls around this essential network. I thank the DOI team that has worked tirelessly on this investigation and the many City entities that provided assistance, including the staff from the City Department of Social Services who worked closely with DOI to support this examination.”
The City, through the City Department of Social Services (“DSS”) and the City Department of Homeless Services (“DHS”), operates the largest homeless shelter system of any municipality in the United States. DHS-funded shelters currently support an average of over 86,000 people per night at a cost of approximately $4 billion annually in FY 2024, up from $2.7 billion annually in FY 2022, due in large part to the influx of asylum seekers over the past two years. (DOI did not review City-funded contracts involving services to the asylum seekers that were procured under emergency procedures for this Report. DOI has oversight of these expenditures through an integrity monitor that is supervised by and reports to DOI.)
The examination for this Report began in 2021, well before the influx of asylum seekers, although some of the providers DOI examined are providing asylum seeker services. DOI’s focus on this area was prompted in part by the investigation of Victor Rivera, the former CEO of nonprofit City service provider Bronx Parent Housing Network, who ultimately pled guilty to a federal bribery-and-kickback scheme involving that nonprofit. DOI investigators drew on their knowledge of financial and administrative vulnerabilities in City-funded nonprofit providers generally to examine individual shelter providers’ governance and compliance practices, and potential conflicts of interest and other potential misconduct during this examination of 51 nonprofit organizations operating shelters for DHS. DOI reviewed the 2 operations of these organizations and their responses to a detailed questionnaire; analyzed an array of materials including audit reports, financial ledgers, invoices, and disclosures to the City; and conducted dozens of interviews, including of certain providers’ senior executives. DOI also evaluated the oversight of these providers by the City, including by DHS and DSS. The provider practices and City oversight reflected in the Report dates from 2018 through the present, although the majority of DOI’s information-gathering was completed from 2022 through 2024.
DOI received approximately 70 responses to the questionnaire distributed to City-funded nonprofit organizations. To date, DOI has completed findings on 51 providers and issued related referral letters to DSS, each one summarizing DOI’s findings as to individual shelter providers and, in total, raising hundreds of governance and compliance concerns at these providers. The findings in these referrals already have caused some providers to make improvements to their policies and procedures. The Report makes 32 recommendations to the relevant City agencies to address system-wide vulnerabilities, strengthen controls with respect to providers to protect the substantial public funds providers receive, and enhance public trust.
Aspects of this examination are still ongoing, and this Report is a summary of DOI’s major findings to date.
This Report builds on the findings from the investigations DOI has conducted in recent years that have focused on the City’s nonprofit vendor spending and which have resulted in criminal charges, administrative findings, integrity monitorships, and recommendations to improve City oversight of these contracts and providers. Since 2018, DOI investigations have resulted in at least 25 arrests on charges involving fraud and corruption at City-funded nonprofits, including prosecutions related to homeless service providers. Since 2018, DOI also has issued more than a dozen administrative referrals to City agencies – in addition to the administrative referrals issued as part of this examination -- reporting findings of mismanagement, noncompliance, or other non-criminal misconduct at City-funded nonprofits.
In 2021, DOI issued Report on Corruption Vulnerabilities in the City’s Oversight and Administration of Not-for-Profit Human Services, which identified gaps in the City’s general oversight of its contracts with nonprofit human service providers. Many of DOI’s prior findings and recommendations remain relevant to the findings of this Report, which focuses solely on the unique issues associated with the oversight of DHSfunded shelter providers.
This Report identifies a variety of compliance and governance risks at these providers, as well as in the City’s overall management of the shelter system. These risks vary in their severity and include:
• Conflicts of interest affecting City money. DOI identified cases where insiders at the shelter provider had personal business interests involving the shelter through which they received payments outside their regular compensation. In some cases, shelter executives simultaneously held employment at a private entity, such as a security company, that was hired to provide services at City-funded shelters.
• Poor Citywide controls over how City money is used for executive compensation. DOI identified multiple shelter executives who received more than $500,000 per year, and in some cases, more than $700,000 per year, from providers and related organizations. Executive compensation in these cases is funded either largely or in part through City funds. The City lacks sufficient rules concerning how much City money can be allocated to nonprofit executives’ salaries.
• Nepotism, in violation of City contracts. DOI found shelter providers that have employed immediate family members of senior executives and board members, in apparent violation of their City contracts. For instance, one provider that is largely funded by the City employed its CEO’s children since at least 2007. This provider subsequently entered into a DOI-managed monitorship agreement.
• Shelter providers failing to follow competitive bidding rules when procuring goods and services with public money. DOI found numerous cases where shelter providers did not comply with the City’s competitive bidding requirements or where it was unclear whether shelter providers conducted true competitive bidding processes. For example, this review identified multiple instances where shelter providers awarded multimillion-dollar building maintenance service contracts to companies affiliated with the buildings’ landlords.
DOI issued 32 recommendations to address the system-wide vulnerabilities noted in this Report. Included among the key recommendations are:
➢ DSS should appoint a Chief Vendor Compliance Officer to provide overall leadership for DSS and DHS’s compliance strategy with respect to nonprofit human service contracts, including contracts with shelter providers.
➢ Shelter providers should be required to regularly disclose additional information relevant to identifying compliance risks, including potential conflicts of interest for key persons.
➢ DSS and DHS should take steps to improve their oversight of shelter operators’ expenditures, including by immediately stopping payments for costs that are not accompanied by a proper description and ensuring that relevant agency staff receive regular financial compliance training.
➢ The City should update its electronic procurement and invoicing systems to better enable thirdparty oversight and centralize key documentation.
This Report also reiterates many of the 23 recommendations that DOI issued in its November 2021 Report on Corruption Vulnerabilities in the City’s Oversight and Administration of Not-for-Profit Human Services. While the City has implemented some reforms since the 2021 Report and is also undertaking some work that closely tracks DOI’s recommendations, many of the recommendations from 2021 have not been implemented at any substantial level. The 2021 Report recommended, among other things, that the City:
Reform its conflict-of-interest disclosure system for the City’s human service providers.
Develop more specific guidance to agencies on executive compensation and consider setting a cap or other parameters on City-funded executive compensation.
Conduct more robust reviews of expenses that human service providers invoice to the City, including by reviewing larger samples of supporting documentation.
New York City is currently making an unprecedented financial commitment to address homelessness. For that reason, it is more important than ever that it implement stronger risk management and compliance controls around this spending. Accepting and implementing the reforms set forth in this Report, as well as in DOI’s November 2021 Report, would be critical steps in this direction.
DOI Commissioner Strauber thanks DSS Commissioner Molly Wasow Park and her staff, for their partnership on this examination and the Mayor’s Office of Contracts and Mayor’s Office of Risk Management and Compliance for their assistance.
DOI also received support from two private firms with experience in investigations, audits, and compliance monitoring, who provided auditing and investigative resources with respect to certain provider reviews.
At DOI, this examination was conducted by Deputy Inspector General/Special Counsel Daniel Kacinski and Confidential Investigator Rushelle Sharpe, with the assistance of Senior Investigative Auditor Olga Avram and Senior Investigative Attorney Alex Cane in DOI’s Office of the Inspector General for CityFunded Nonprofits. Data Analysts Anthony McDowald and Zachary Sayle and Director of Data Analytics Shyam Prasad in DOI’s Data Analytics Unit provided technical assistance. The examination was supervised 4 by Senior Inspector General Andrew Sein, Deputy Commissioner of Strategic Initiatives Christopher Ryan, and Deputy Commissioner/ Chief of Investigations Dominick Zarrella.
https://www.nyc.gov/assets/doi/press-releases/2024/October/39DHSRptRelease10.17.2024.pdf
纽约社会福利腐败不是一天两天， 川普爷爷是穷光蛋，川普爹发迹就是靠给贫民盖廉价屋，贪污克扣。