The difference comes from the federal government, which employs Graziano—indirectly—as the Executive Director of the Housing Authority of Baltimore City, a state-chartered agency overseeing 12,600 units of public housing.
City Paper looked at the federal disclosure of the public housing agency last week and noted that Graziano's federal pay was listed at roughly $122,000, plus a $60,000 bonus.
Added to his reported city pay of $153,000, Graziano's total pay package would appear to top $330,000.
But that's wrong, Baltimore Housing spokeswoman Tania Baker said in an email to City Paper, which demanded a retraction of the blog post that reported the figure. Baker went on to explain that $151,900 of Graziano's $214,300 pay package "is received through the City payroll and $62,400 is paid through HABC's payroll."
That could explain why the city-reported figure is what it is. But what of the federal figure—which is almost triple the $62,400 Baker says?
Baker explains the discrepancy by noting that, because of the bifurcated nature of his job (he heads both the city agency that does things such as building and housing code inspections, and the housing authority itself, which operates under the state and federal umbrella), Graziano's pay is divided 60-40 between the federal government and the city, "based on the scale of the respective operations."
That means, Baker writes, that the city's actual share of Graziano's pay is but $85,720, while the HABC's actual share is $128,580.
That latter figure is sort of close to the $122,075 as reported by the federal government, but how to account for the $59,694 bonus the feds report Graziano earned?
Baker goes on to say that "HUD refers to all non-salary payments as a bonus," while "in fact," HABC paid Graziano $23,500 in "deferred compensation" and $36,000 as "Life insurance/annuity."
She did not respond to requests for a follow-up conversation seeking more detail.
HUD spokesman Jerry Brown, meanwhile, said Baker was mistaken about the nature of Graziano's "bonus."
"If it's not a bonus, it shouldn't be listed as one," Brown says in an email. "I also have life insurance provided by HUD. It's listed as life insurance."
Deferred compensation plans and life insurance annuities are two common methods by which high-earning people avoid taxes and build retirement nest eggs by deferring part of their cash salaries.
All this means that citizens wanting to compare the salaries of public officials are basically out of luck. The reported figures look authoritative, down to the dollar. But they aren't really, and even the experts say they don't know for sure what counts as cash compensation and what doesn't under the rules.
"I'm less troubled by whether he makes $214,000 or $275,000 than I am by how hard it is to find out," says City Councilman Bill Henry (4th District), who heads the council's Housing and Community Development Committee.
The federal law requiring public housing agencies to disclose the pay of their top people dates back to 2011. It was prompted by the discovery that the head of Atlanta's public housing authority was making more than $600,000 per year. Los Angeles' housing chief also banked more than $600,000, and the director of the Philadelphia public housing authority, Carl Greene, made more than $300,000. That was called a scandal because it was $105,000 more than Mayor Michael Nutter.
The new law capped public housing agency pay at $155,000—sort of. Agencies could pay more if they had funding from sources other than the federal Section 8 and Section 9 programs—the two main sources of HUD funding. Many housing authorities do have other sources of income, Brown says. They include rental receipts from nonprofit housing developers the agency charters, and money from other programs. HUD, for instance, instituted a program called Moving to Work, which allows top-performing city housing authorities to allocate federal funds as a sort of block grant to best house the most people. Baltimore is part of that program.
Before the scandal over Greene's pay, at least, Philadelphia was too.
The federal pay disclosure law requires public housing authorities to report the source of any executive's pay that exceeds $155,000. In her email, Baker says Graziano's pay complies with the cap.
With the new pay disclosure law, which Congress made permanent in 2014, the reported pay figures for public housing authority chiefs came down.
But the figures don't mean much, says Tamar Greenspan, the director of policy and program development for the National Association of Housing and Redevelopment Officials (NAHRO), because HUD has not been clear or consistent about what compensation should be reported. "So originally [the form] did not include bonuses," she says. "That was something of a loophole, so later it was changed to include salary and bonuses."
NAHRO fought the law fiercely, arguing that it required public housing authorities to divulge information that other federal contractors did not, and that the law would be burdensome to comply with. The organization—which claims 18,000 members—went so far as to demand the pay information from HUD officials under the Freedom of Information Act, and construct a dedicated website to publicize those.
Greenspan says that even if the form required by law was consistent over time, the data reported would not be comparable from city to city. That's because costs of living vary, she says, but it is also because the accounting system HUD requires public housing authorities to use makes it difficult—if not impossible—to determine the sources of the various funds that make up a given executive's paycheck. "The form asks for information in a form that is not readily available in the accounting system HUD requires us to use," she says.
A system-wide accounting change in 2007 caused one problem, Greenspan says, when housing authorities were told to manage their buildings on a project-by-project bases, instead of portfolio-wide. This brought about another accounting system which involved a "central office cost center," which charges for management of a housing authority's various buildings and other assets. Management fees charged this way didn't count under the federal cap at first, Greenspan says. And then they did.
"But housing authorities have not always kept track of where these dollars came from," Greenspan says. "The attitude is, 'once I have it, it's my money now, so it's mine. Doesn't matter if it's my paycheck or a gift from grandma.'"
Baltimore's system is likely more complex yet, given Graziano's other duties that are entirely separate from his job as head of the HABC.
"There are all these accounting issues about what is supposed to be on the forms," Greenspan says. "Any individual who is wearing multiple hats with the same employer is going to be particularly hard to figure out. You picked a particularly hard one. If you were from Topeka, Kansas it would probably have been substantially simpler."
Bill Henry adds, "Agency heads are compensated on a level that is typically less than they would make in the private sector, but the purpose of reporting compensation of these officials is missed if it's too difficult for someone looking for that information to get it."