2023-003 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: The Entity received ICDBG Imminent Threat (IT) funding under American Rescue Plan Act of
2021. To be allowable under IT funding, expenditures must be used for emergencies that constitute threats
to health and safety and that are designed to prevent, prepare for, or respond to coronavirus.
Condition: We found five expenditures totaling $13,910 that were for rehabilitation and repair work on a
vacant housing unit owned by the Entity. There was no source documentation to support these expenditures
were used for an emergency threat in preventing, preparing or responding to coronavirus.
Questioned Costs: None.
Context: Five out of 27 non-payroll transactions tested for the ICGB program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were appropriate and in accordance with ICDBG activities allowed/unallowed and
allowable costs/cost principles requirements. As a result, the Entity was not in compliance with these
federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are appropriate and permissible under the provisions of the award agreement. This includes reviewing
award agreements and program budgets/proposals that have been approved by the funding agency to ensure
expenditures charged to federal award are allowable.
Management’s Response: Management will improve its internal controls and procedures in place to ensure
that expenditures charged to federal award are appropriate and permissible under the provisions of the
award agreement.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-004 – Procurement and Suspension and Debarment
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: For purchases between $10,001 and $250,000, NPHE’s procurement policy requires competitive
negotiations and bids from a reasonable number of competitive sources. Additionally, a tabulation of
solicitations made and quotations received shall be kept on file. Furthermore, vendors awarded contracts of
$25,000 or more are required to be checked for suspension and debarment via the federal System for
Award Management (SAM.gov).
Condition: During our assessment of 27 ICDBG non-payroll transactions we found the following:
• Six expenditures were missing documentation to support competitive negotiations and bids we
obtained from a reasonable number of competitive sources.
• Eight expenditures for vendor contracts over $25,000 were missing documentation to support that a
suspension and debarment check was performed via SAM.gov.
Questioned Costs: None.
Context: Six out of 27 non-payroll transactions tested for procurement under the ICGB program. Eight out
of 27 non-payroll transactions tested for suspension and debarment under the ICDBG program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were properly procured and vendors paid were checked for suspension and debarment in
accordance with the Entity and federal requirements. As a result, the Entity was not in compliance with
these federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are properly procured and vendors are checked for suspension and debarment in accordance with the
Entity’s policies and procedures and federal requirements.
Management’s Response: NPHE will review and update the procurement policies to ensure that they
clearly outline the requirements for competitive negotiations and bids.
We will conduct training sessions as needed for all relevant staff to reinforce the importance of obtaining
and retaining documentation for competitive negotiations and bids. This training will include best practices
for procurement and record-keeping. We will also establish a standardized process for conducting
suspension and debarment checks on SAM.gov and ensure that documentation of the check is included in
the procurement file.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-003 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: The Entity received ICDBG Imminent Threat (IT) funding under American Rescue Plan Act of
2021. To be allowable under IT funding, expenditures must be used for emergencies that constitute threats
to health and safety and that are designed to prevent, prepare for, or respond to coronavirus.
Condition: We found five expenditures totaling $13,910 that were for rehabilitation and repair work on a
vacant housing unit owned by the Entity. There was no source documentation to support these expenditures
were used for an emergency threat in preventing, preparing or responding to coronavirus.
Questioned Costs: None.
Context: Five out of 27 non-payroll transactions tested for the ICGB program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were appropriate and in accordance with ICDBG activities allowed/unallowed and
allowable costs/cost principles requirements. As a result, the Entity was not in compliance with these
federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are appropriate and permissible under the provisions of the award agreement. This includes reviewing
award agreements and program budgets/proposals that have been approved by the funding agency to ensure
expenditures charged to federal award are allowable.
Management’s Response: Management will improve its internal controls and procedures in place to ensure
that expenditures charged to federal award are appropriate and permissible under the provisions of the
award agreement.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-004 – Procurement and Suspension and Debarment
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: For purchases between $10,001 and $250,000, NPHE’s procurement policy requires competitive
negotiations and bids from a reasonable number of competitive sources. Additionally, a tabulation of
solicitations made and quotations received shall be kept on file. Furthermore, vendors awarded contracts of
$25,000 or more are required to be checked for suspension and debarment via the federal System for
Award Management (SAM.gov).
Condition: During our assessment of 27 ICDBG non-payroll transactions we found the following:
• Six expenditures were missing documentation to support competitive negotiations and bids we
obtained from a reasonable number of competitive sources.
• Eight expenditures for vendor contracts over $25,000 were missing documentation to support that a
suspension and debarment check was performed via SAM.gov.
Questioned Costs: None.
Context: Six out of 27 non-payroll transactions tested for procurement under the ICGB program. Eight out
of 27 non-payroll transactions tested for suspension and debarment under the ICDBG program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were properly procured and vendors paid were checked for suspension and debarment in
accordance with the Entity and federal requirements. As a result, the Entity was not in compliance with
these federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are properly procured and vendors are checked for suspension and debarment in accordance with the
Entity’s policies and procedures and federal requirements.
Management’s Response: NPHE will review and update the procurement policies to ensure that they
clearly outline the requirements for competitive negotiations and bids.
We will conduct training sessions as needed for all relevant staff to reinforce the importance of obtaining
and retaining documentation for competitive negotiations and bids. This training will include best practices
for procurement and record-keeping. We will also establish a standardized process for conducting
suspension and debarment checks on SAM.gov and ensure that documentation of the check is included in
the procurement file.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-005 – Eligibility
Federal Program Information:
Funding Agency: U.S. Department of the Treasury
Title: Homeowner Assistance Fund Program (HAF)
Assistance Listing Number: 21.026
Award Period: October 1, 2022 – September 30, 2023
Criteria: To receive assistance under the HAF program, homeowners must have experienced a financial
hardship after January 21, 2020 and have an income less equal to or less than 150% of the area median
income or 100% of the median income for the United States, whichever is greater.
Condition: During our assessment of 19 homeowners that received assistance, we found the following:
• One homeowner had a household income greater than the income eligibility limits. The homeowner
had a household income of 118% and 113% of the median incomes for the local area and United
States, respectively.
• 19 homeowners did not have an application and other documentation attesting to the financial
hardship experienced.
• One homeowner did not have documentation to support the income eligibility determination
performed by the Entity.
Questioned Costs: None
Context: 19 out of 19 homeowners tested that received assistance under the HAF program.
Cause and Effect: The Entity did not follow its internal controls for ensuring homeowners were
appropriately screened for income eligibility and for ensuring adequate documentation was maintained to
support all eligibility requirements were met by applicants. As a result, NPHE was not in compliance with
the eligibility requirements of the HAF program.
Auditors’ Recommendation: Improve internal controls to ensure all HAF program eligibility requirements
are met and documented for all applicants. This includes developing policies and procedures for
maintaining and retaining applications for assistance and other source documentation to support the
eligibility determination process conducted.
Management’s Response: Nambe Pueblo Housing Entity (NPHE) will develop comprehensive policies and
procedures for maintaining and retaining applications for assistance, as well as all other source
documentation necessary to support the eligibility determination process. This initiative aims to ensure
accuracy, transparency, and compliance with regulatory requirements throughout the eligibility assessment.
The enhanced documentation process will provide a robust framework to verify applicant eligibility,
maintain records for auditing purposes, and improve overall operational efficiency.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-006 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of the Treasury
Title: Homeowner Assistance Fund Program (HAF)
Assistance Listing Number: 21.026
Award Period: October 1, 2022 – September 30, 2023
Criteria: The HAF program requires quarterly (financial) and annual (performance) reporting. Reports are
due 45 calendar days after the reporting period.
Condition: During our assessment of two quarterly financial reports and one annual performance report we
found the following:
• Two quarterly financial reports did not have source documentation to support that the reports were
prepared and submitted timely.
• One annual report did not have source documentation to support that the report was prepared and
submitted timely.
Questioned Costs: None
Context: Two of two quarterly financial reports and one out of one annual performance report tested for the
HAF program.
Cause and Effect: The Entity experienced turnover at the Executive Director position. The previous
Executive Director was responsible for performing and submitting the required HAF program reports via
the U.S. Department of the Treasury’s online reporting portal. The Entity is certain that the reports were
filed, however source documentation to support the preparation and submission was not maintained and
available for review. Additionally, the Entity was unable to re-establish access to the U.S. Department of
the Treasury’s online reporting portal to print copies of the reports and provide for audit. As a result, NPHE
is not in compliance with the reporting requirements of the HAF program.
Auditors’ Recommendation: Improve internal controls to ensure source documentation is maintained to
support the preparation and timely submission of the reports required under the HAF program.
Management should also work with the U.S. Department of the Treasury to re-establish access to the online
reporting portal.
Management’s Response: Management will work with the U.S. Department of the Treasury to re-establish
access to the online reporting portal. NPHE will also print copies of all reports filed to ensure that reports
are readily available for inspection.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-003 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: The Entity received ICDBG Imminent Threat (IT) funding under American Rescue Plan Act of
2021. To be allowable under IT funding, expenditures must be used for emergencies that constitute threats
to health and safety and that are designed to prevent, prepare for, or respond to coronavirus.
Condition: We found five expenditures totaling $13,910 that were for rehabilitation and repair work on a
vacant housing unit owned by the Entity. There was no source documentation to support these expenditures
were used for an emergency threat in preventing, preparing or responding to coronavirus.
Questioned Costs: None.
Context: Five out of 27 non-payroll transactions tested for the ICGB program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were appropriate and in accordance with ICDBG activities allowed/unallowed and
allowable costs/cost principles requirements. As a result, the Entity was not in compliance with these
federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are appropriate and permissible under the provisions of the award agreement. This includes reviewing
award agreements and program budgets/proposals that have been approved by the funding agency to ensure
expenditures charged to federal award are allowable.
Management’s Response: Management will improve its internal controls and procedures in place to ensure
that expenditures charged to federal award are appropriate and permissible under the provisions of the
award agreement.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-004 – Procurement and Suspension and Debarment
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: For purchases between $10,001 and $250,000, NPHE’s procurement policy requires competitive
negotiations and bids from a reasonable number of competitive sources. Additionally, a tabulation of
solicitations made and quotations received shall be kept on file. Furthermore, vendors awarded contracts of
$25,000 or more are required to be checked for suspension and debarment via the federal System for
Award Management (SAM.gov).
Condition: During our assessment of 27 ICDBG non-payroll transactions we found the following:
• Six expenditures were missing documentation to support competitive negotiations and bids we
obtained from a reasonable number of competitive sources.
• Eight expenditures for vendor contracts over $25,000 were missing documentation to support that a
suspension and debarment check was performed via SAM.gov.
Questioned Costs: None.
Context: Six out of 27 non-payroll transactions tested for procurement under the ICGB program. Eight out
of 27 non-payroll transactions tested for suspension and debarment under the ICDBG program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were properly procured and vendors paid were checked for suspension and debarment in
accordance with the Entity and federal requirements. As a result, the Entity was not in compliance with
these federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are properly procured and vendors are checked for suspension and debarment in accordance with the
Entity’s policies and procedures and federal requirements.
Management’s Response: NPHE will review and update the procurement policies to ensure that they
clearly outline the requirements for competitive negotiations and bids.
We will conduct training sessions as needed for all relevant staff to reinforce the importance of obtaining
and retaining documentation for competitive negotiations and bids. This training will include best practices
for procurement and record-keeping. We will also establish a standardized process for conducting
suspension and debarment checks on SAM.gov and ensure that documentation of the check is included in
the procurement file.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-003 – Activities Allowed/Unallowed and Allowable Costs/Cost Principles
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: The Entity received ICDBG Imminent Threat (IT) funding under American Rescue Plan Act of
2021. To be allowable under IT funding, expenditures must be used for emergencies that constitute threats
to health and safety and that are designed to prevent, prepare for, or respond to coronavirus.
Condition: We found five expenditures totaling $13,910 that were for rehabilitation and repair work on a
vacant housing unit owned by the Entity. There was no source documentation to support these expenditures
were used for an emergency threat in preventing, preparing or responding to coronavirus.
Questioned Costs: None.
Context: Five out of 27 non-payroll transactions tested for the ICGB program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were appropriate and in accordance with ICDBG activities allowed/unallowed and
allowable costs/cost principles requirements. As a result, the Entity was not in compliance with these
federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are appropriate and permissible under the provisions of the award agreement. This includes reviewing
award agreements and program budgets/proposals that have been approved by the funding agency to ensure
expenditures charged to federal award are allowable.
Management’s Response: Management will improve its internal controls and procedures in place to ensure
that expenditures charged to federal award are appropriate and permissible under the provisions of the
award agreement.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-004 – Procurement and Suspension and Debarment
Federal Program Information:
Funding Agency: U.S. Department of Housing and Urban Development
Title: Indian Community Development Block Grant (ICDBG)
Assistance Listing Number: 14.862
Award Period: October 1, 2022 – September 30, 2023
Criteria: For purchases between $10,001 and $250,000, NPHE’s procurement policy requires competitive
negotiations and bids from a reasonable number of competitive sources. Additionally, a tabulation of
solicitations made and quotations received shall be kept on file. Furthermore, vendors awarded contracts of
$25,000 or more are required to be checked for suspension and debarment via the federal System for
Award Management (SAM.gov).
Condition: During our assessment of 27 ICDBG non-payroll transactions we found the following:
• Six expenditures were missing documentation to support competitive negotiations and bids we
obtained from a reasonable number of competitive sources.
• Eight expenditures for vendor contracts over $25,000 were missing documentation to support that a
suspension and debarment check was performed via SAM.gov.
Questioned Costs: None.
Context: Six out of 27 non-payroll transactions tested for procurement under the ICGB program. Eight out
of 27 non-payroll transactions tested for suspension and debarment under the ICDBG program.
Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the
ICDBG program were properly procured and vendors paid were checked for suspension and debarment in
accordance with the Entity and federal requirements. As a result, the Entity was not in compliance with
these federal requirements for the ICDBG program.
Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award
are properly procured and vendors are checked for suspension and debarment in accordance with the
Entity’s policies and procedures and federal requirements.
Management’s Response: NPHE will review and update the procurement policies to ensure that they
clearly outline the requirements for competitive negotiations and bids.
We will conduct training sessions as needed for all relevant staff to reinforce the importance of obtaining
and retaining documentation for competitive negotiations and bids. This training will include best practices
for procurement and record-keeping. We will also establish a standardized process for conducting
suspension and debarment checks on SAM.gov and ensure that documentation of the check is included in
the procurement file.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-005 – Eligibility
Federal Program Information:
Funding Agency: U.S. Department of the Treasury
Title: Homeowner Assistance Fund Program (HAF)
Assistance Listing Number: 21.026
Award Period: October 1, 2022 – September 30, 2023
Criteria: To receive assistance under the HAF program, homeowners must have experienced a financial
hardship after January 21, 2020 and have an income less equal to or less than 150% of the area median
income or 100% of the median income for the United States, whichever is greater.
Condition: During our assessment of 19 homeowners that received assistance, we found the following:
• One homeowner had a household income greater than the income eligibility limits. The homeowner
had a household income of 118% and 113% of the median incomes for the local area and United
States, respectively.
• 19 homeowners did not have an application and other documentation attesting to the financial
hardship experienced.
• One homeowner did not have documentation to support the income eligibility determination
performed by the Entity.
Questioned Costs: None
Context: 19 out of 19 homeowners tested that received assistance under the HAF program.
Cause and Effect: The Entity did not follow its internal controls for ensuring homeowners were
appropriately screened for income eligibility and for ensuring adequate documentation was maintained to
support all eligibility requirements were met by applicants. As a result, NPHE was not in compliance with
the eligibility requirements of the HAF program.
Auditors’ Recommendation: Improve internal controls to ensure all HAF program eligibility requirements
are met and documented for all applicants. This includes developing policies and procedures for
maintaining and retaining applications for assistance and other source documentation to support the
eligibility determination process conducted.
Management’s Response: Nambe Pueblo Housing Entity (NPHE) will develop comprehensive policies and
procedures for maintaining and retaining applications for assistance, as well as all other source
documentation necessary to support the eligibility determination process. This initiative aims to ensure
accuracy, transparency, and compliance with regulatory requirements throughout the eligibility assessment.
The enhanced documentation process will provide a robust framework to verify applicant eligibility,
maintain records for auditing purposes, and improve overall operational efficiency.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024
2023-006 – Reporting
Federal Program Information:
Funding Agency: U.S. Department of the Treasury
Title: Homeowner Assistance Fund Program (HAF)
Assistance Listing Number: 21.026
Award Period: October 1, 2022 – September 30, 2023
Criteria: The HAF program requires quarterly (financial) and annual (performance) reporting. Reports are
due 45 calendar days after the reporting period.
Condition: During our assessment of two quarterly financial reports and one annual performance report we
found the following:
• Two quarterly financial reports did not have source documentation to support that the reports were
prepared and submitted timely.
• One annual report did not have source documentation to support that the report was prepared and
submitted timely.
Questioned Costs: None
Context: Two of two quarterly financial reports and one out of one annual performance report tested for the
HAF program.
Cause and Effect: The Entity experienced turnover at the Executive Director position. The previous
Executive Director was responsible for performing and submitting the required HAF program reports via
the U.S. Department of the Treasury’s online reporting portal. The Entity is certain that the reports were
filed, however source documentation to support the preparation and submission was not maintained and
available for review. Additionally, the Entity was unable to re-establish access to the U.S. Department of
the Treasury’s online reporting portal to print copies of the reports and provide for audit. As a result, NPHE
is not in compliance with the reporting requirements of the HAF program.
Auditors’ Recommendation: Improve internal controls to ensure source documentation is maintained to
support the preparation and timely submission of the reports required under the HAF program.
Management should also work with the U.S. Department of the Treasury to re-establish access to the online
reporting portal.
Management’s Response: Management will work with the U.S. Department of the Treasury to re-establish
access to the online reporting portal. NPHE will also print copies of all reports filed to ensure that reports
are readily available for inspection.
Responsible Party: Interim Executive Director
Anticipated Completion: July 2024