Audit Report on the New York City Housing Authority’s Controls over Heat Maintenance
The New York City Housing Authority (NYCHA), the largest public housing authority in the United States, was created in 1935 to provide decent, affordable housing for low- and moderate-income New Yorkers. According to data published by NYCHA, as of 2019, more than 370,000 New Yorkers resided in NYCHA’s 316 public housing developments located throughout the five boroughs of New York City (City), comprising 2,351 buildings that contain 173,762 units. NYCHA has established standard operating procedures (SOPs) that set forth the agency’s internal operating procedures governing a wide variety of areas.
Among other things, NYCHA’s heating SOPs mandate that NYCHA is required to provide heat to its residents between October 1st and May 31st, (i.e., the heating season) when the temperature falls below 55 degrees Fahrenheit.[1] NYCHA requires that its staff respond to heat-related complaints within 24 hours. Responding to a complaint does not, however, necessarily mean that the complaint will be resolved within 24 hours, but rather means that steps to assess the heating issue complained of will be initiated within 24 hours. Depending on the circumstances, resolving the complaint itself and restoring heat may take longer. Once a complaint identifying the need for a repair (heat-related or otherwise) is received by NYCHA, it is entered into Siebel, NYCHA’s computer software system used for scheduling appointments.[2] The complaint is then automatically uploaded from Siebel into Maximo, NYCHA’s computer software system used for generating work orders and for tracking the status of repair work orders.[3] Heat-related work orders are categorized as “NOHEAT” in Maximo.
If NYCHA, upon investigation of a resident’s complaint, determines that the concern is related to a system-wide heat failure (e.g., affecting an entire development, building, apartment line or stair hall), the corrective maintenance work order will be closed and an “outage work order” will be opened. According to NYCHA’s records, there were 167,752 no-heat work orders created during the 2017-2018 heating season as a result of complaints made by residents. Of these, 81,997 (49%) were related to 1,776 outages (i.e., system-wide heating failures). This means that 85,755 (51%) no-heat work orders were heating complaints unrelated to outages.
Audit Findings and Conclusions
The tools used by NYCHA’s central management to oversee and track heating issues are inefficient and ineffective. As a result, NYCHA is significantly hindered in its ability to manage and resolve heating issues.
NYCHA does not have the ability to readily track the status and resolution of repairs required to respond to heating complaints that are not the result of system-wide heating failures (i.e., outages). Rather, for such heating complaints stemming from issues that affect individual units and not larger areas, Maximo only tracks the closure of individual work orders and not the amount of time it takes to successfully resolve these heat-related complaints. This practice is particularly problematic because individual unit heat-related complaints may require the opening and closing of multiple work orders before the issues complained of are ultimately resolved. As a result, among other things, NYCHA management cannot readily identify the number of unresolved heat-related complaints open at any one time nor can it readily determine the length of time it took to ultimately resolve those complaints. Absent such information, NYCHA’s ability to identify problems that delay repairs is undermined and, as a result, NYCHA is significantly hindered in its ability to determine how to most effectively allocate resources, make operational changes, and enhance training and oversight in order to address problems.
Additionally, we found that NYCHA does not have adequate procedures for independently verifying the accuracy of the repair information that staff records in Maximo. As a result, the degree to which the repair-related data reported in the system can be relied upon is questionable.
Further, the audit found that NYCHA does not maintain complete inventory listings of all the boilers currently in its developments, which undermines the agency’s ability to properly manage its inventory. Absent a comprehensive, accurate listing of the boilers that includes essential identifying and other information, such as the dates of installation, asset numbers, makes and models, warranty information, as well as each boiler’s inspection and repair histories, NYCHA cannot efficiently ensure that all inspections are properly made and that decisions about the need and timing of replacements are made with complete information.
The audit found that NYCHA also does not maintain adequate records of mandated external and internal boiler inspections in a manner that enables the agency to track the status of those inspections and ensure that all required inspections are completed. Moreover, during our audit period, NYCHA did not maintain adequate records that deficiencies identified in these inspections had been addressed. With regard to preventive maintenance inspections, according to data contained in Maximo, for the 2017-2018 heating season, NYCHA conducted only 84 percent of the required inspections. However, we were unable to identify the specific work orders created to address the deficiencies cited during those inspections—and the disposition of those work orders—because NYCHA did not have a way to identify such orders. As a result, neither we nor NYCHA could determine whether work identified through the preventive maintenance inspections was ever satisfactorily performed.
Under present circumstances, NYCHA’s persistent failure to adequately resolve heating issues will continue unless management addresses the deficiencies we found and establishes systems that enable it to reliably track the causes and occurrences of heating problems, equipment conditions and deficiencies, along with the timing and adequacy of repairs, including whether work was properly done.
Audit Recommendations
To address the issues raised by this audit, we make eight recommendations, including that:
- NYCHA should create a mechanism for it to efficiently track all heat-related complaints, including those that are not caused by system-wide outages, from receipt of a complaint to its final disposition so that the agency can efficiently and effectively determine, among other things, the time it takes to resolve such complaints, identify aging complaints, address languishing complaints, and improve systems that lead to delayed resolutions of complaints.
- NYCHA should maintain a complete and updated inventory listing of boilers with unique identifying information to better enable NYCHA to track and monitor issues relating to each boiler.
- NYCHA should establish a formal system for documenting its tracking of all boilers that require inspections and the status of such inspections so as to ensure that all boilers receive the required internal, external, and preventive maintenance inspections in a timely manner and that deficiencies found during the inspections are corrected within the time frames mandated by applicable law, rules, regulations, and agreements with external oversight agencies.
- NYCHA should continue its efforts to develop a tracking system that would allow it to identify the work orders created to address deficiencies identified during inspections so as to be able to track the repairs and the timeliness of those repairs.
Agency Response
In its response, NYCHA agreed without any qualifications with three recommendations: that it analyze the feedback it receives from residents with regard to their satisfaction with heating-related work (#4); that it ensure it disseminates its inventory listing to all of its operational units involved in processes related to the boilers (#6); and that it continue its efforts to develop a tracking system to identify work orders created to address deficiencies identified through boiler inspections (#8).
In addition, NYCHA agreed with the following four recommendations in principle, but claimed that it was already in compliance with each: that NYCHA create a mechanism to efficiently track all heat-related complaints (#1); that it monitor the adequacy of its staffing levels (#2); that it maintain a complete and updated inventory listing of boilers with unique identifying information (#5); and that it establish a formal system for documenting its tracking of all boilers that require inspections (#7). By asserting that the agency’s current practices are consistent with the recommendations, however, NYCHA has effectively rejected the auditors’ recommendations that its current practices need to be improved. Finally, NYCHA failed to directly address recommendation #3, that it develop a process whereby supervisors are required to follow up on a prescribed number of closed out work orders and confirm that the work reported as completed was conducted as reported.
In its response, NYCHA strongly objects to the audit’s findings and overall assessment that the tools used by NYCHA’s central management to oversee and track heating issues are inefficient and ineffective. Its rejection of the audit’s findings is primarily based on three arguments. First, NYCHA contends that the report fails to acknowledge the improvements the agency has made since the 2017-2018 heating season. In particular, NYCHA claims that it has implemented a number of new initiatives and procedural changes with the collaboration and approval of the independent Federal Monitor. However, to support its claims, NYCHA misleadingly cites recently developed policies and procedures that apply only to heating outages (e.g., system-wide heat losses that affect entire developments and buildings) in response to the audit’s identification of deficiencies in NYCHA’s handling of individual heat-related complaints (e.g., heat loss complaints that affect only individual apartment units). Consequently, the changes NYCHA cites do not resolve the problems that underlie key findings of this report. Among other things, NYCHA remains unable to determine how many units are experiencing heat-related issues at any given point in time. In addition, it is unable to tell how long it takes to resolve heating issues that are not related to outages. Further, NYCHA failed to provide any evidence that it is able to independently verify the repair information that staff records in Maximo.
Second, NYCHA incorrectly argues that the audit’s findings related only to the 2017-2018 heating season and, based largely on that misstatement, are outdated. However, as is clearly set forth in the report, the audit scope period was January 1, 2017 through May 31, 2019. Moreover, we requested and accepted evidence up to and after the February 24, 2020 exit conference where we discussed the audit’s preliminary findings. Although the data we analyzed related to heat-related complaints and outages primarily relates to the 2017-2018 heating season, NYCHA has provided no evidence—although requested—that the operational weaknesses cited in the report have been corrected.[4] As discussed in detail below, the findings of deficiencies identified in this audit for that period unfortunately remain relevant to this day. Moreover, the audit’s findings and recommendations related to NYCHA’s boiler inventory and boiler inspections expressly address issues that existed beyond the 2017-2018 heating season up to and after the February 24, 2020 exit conference. These issues include NYCHA’s failure to maintain and appropriately disseminate a complete and comprehensive inventory of its boilers, and NYCHA’s failure to properly track repairs made to address deficiencies identified through inspections.
Finally, NYCHA argues that current data reflects that it has a lower number of heating service disruptions and quicker complaint response rates that demonstrate its operations have improved. However, NYCHA’s argument fails to take into account the fact that the 2017-2018 heating season was significantly colder than the two that followed it. According to data reported on the National Weather Service’s website, there were 21 days during December 2017 – February 2018 in which the maximum temperature in the City was below freezing. By comparison, there were only 8 days and 3 days, respectively, of subfreezing temperatures during December 2018 – February 2019 and December 2019 – February 2020. Thus, lower number of service disruptions and quicker service times in the most recent two years must be analyzed in the context of the different weather conditions in those periods in order for them to be properly compared with the much colder 2017-2018 audit scope period. Moreover, the response time rate is of limited relevance because (1) the rate pertains only to work orders generated in response to outages and (2) NYCHA is measuring only the time it took to respond to work orders, rather than the time it expended to resolve the problems upon which the complaints are based. Thus, NYCHA does not know whether there has been any improvement since the 2017-2018 heating season in its timeliness in actually resolving heat-related complaints.
NYCHA makes a number of other arguments in its response; those topics not addressed in our comments relating to NYCHA’s responses to our recommendations are discussed in the Appendix of this report. After carefully reviewing NYCHA’s arguments, we find no basis to alter any of the report’s findings or conclusions.
Endnotes
[1] NYCHA’s heating SOPs refer to the New York City Administrative Code, Title 27, Chapter 21 Article 8, § 27-2029 and Section 79(1) of New York State Multiple Dwelling Law with regards to the provision of heat.
[2] Complaints are automatically uploaded into Siebel if they originate from any source other than a phone call or a walk-in center. Complaints resulting from phone calls and at walk-in centers must be entered manually into Siebel.
[3] NYCHA tracks the status of all work orders through Maximo, but not necessarily the resolution of the complaint. A complaint may require several different crafts and specialists; therefore, several different work orders may need to be opened before the complaint can be resolved.
[4] Notably, the audit’s focus on heat-related complaints made in the 2017-2018 heating season resulted from NYCHA’s failure to produce relevant materials to the auditors in a timely manner. NYCHA’s inexplicable delays producing routine business records necessitated the Comptroller’s Office to issue two separate subpoenas after which the bulk of the records were produced.