(?SEMAP?), it was noted that the Authority lacked the proper documentation and organization to support the self-assessed score that was reported for each indicator, regarding the minimum sample size and the sampling methodology from the correct universe in an unbiased manner. Criteria: 24 CFR 985 requires that the Authority annually submit a SEMAP certification that follows HUD requirements. According to 24 CFR 985.1, SEMAP is designed to determine whether the Section 8 tenant-based assistance programs operate to help eligible families afford decent rental units at the correct subsidy cost. SEMAP provides procedures for HUD to identify PHA management capabilities and deficiencies in order to target monitoring and program assistance more effectively. 24 CFR 985.2 identifies the required minimum sample size for each sub-indicator and requires that the sample is selected in an unbiased manner. Context: The auditor obtained support for the SEMAP submission to test the adequacy of the responses for each indicator. The supporting documentation did not include the correct sample size for several indicators nor did it correctly utilize the information that comes from the Public and Indian Housing Information Center (?PIC?). Cause: Lack of proper oversight and staff training contributed to SEMAP being improperly performed. Effect: The program?s quality control is not being utilized in the most effective manner. The Authority may not be in full compliance with applicable HUD regulations and could receive an inaccurate overall performance rating. Without proper completion of the SEMAP submission, HUD is not able to accurately perform their oversight of the Housing Choice Voucher program. Questioned Costs: None. Auditor Recommendations: The Authority should assign SEMAP responsibilities to a responsible person and provide sufficient training to complete an accurate and complete certification with supporting documentation that meets the requirements of the HUD rules and regulations. The Authority needs to provide the appropriate documentation and support for testing for each of the SEMAP indicators. The Authority should also develop a system to maintain the organization of this documentation which should clearly support the self-assessed scores reported on SEMAP. We recommend SEMAP testing be performed throughout the year and that the Authority use the SEMAP performance analysis to assess and improve their own program operations and performance. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.
(?SEMAP?), it was noted that the Authority lacked the proper documentation and organization to support the self-assessed score that was reported for each indicator, regarding the minimum sample size and the sampling methodology from the correct universe in an unbiased manner. Criteria: 24 CFR 985 requires that the Authority annually submit a SEMAP certification that follows HUD requirements. According to 24 CFR 985.1, SEMAP is designed to determine whether the Section 8 tenant-based assistance programs operate to help eligible families afford decent rental units at the correct subsidy cost. SEMAP provides procedures for HUD to identify PHA management capabilities and deficiencies in order to target monitoring and program assistance more effectively. 24 CFR 985.2 identifies the required minimum sample size for each sub-indicator and requires that the sample is selected in an unbiased manner. Context: The auditor obtained support for the SEMAP submission to test the adequacy of the responses for each indicator. The supporting documentation did not include the correct sample size for several indicators nor did it correctly utilize the information that comes from the Public and Indian Housing Information Center (?PIC?). Cause: Lack of proper oversight and staff training contributed to SEMAP being improperly performed. Effect: The program?s quality control is not being utilized in the most effective manner. The Authority may not be in full compliance with applicable HUD regulations and could receive an inaccurate overall performance rating. Without proper completion of the SEMAP submission, HUD is not able to accurately perform their oversight of the Housing Choice Voucher program. Questioned Costs: None. Auditor Recommendations: The Authority should assign SEMAP responsibilities to a responsible person and provide sufficient training to complete an accurate and complete certification with supporting documentation that meets the requirements of the HUD rules and regulations. The Authority needs to provide the appropriate documentation and support for testing for each of the SEMAP indicators. The Authority should also develop a system to maintain the organization of this documentation which should clearly support the self-assessed scores reported on SEMAP. We recommend SEMAP testing be performed throughout the year and that the Authority use the SEMAP performance analysis to assess and improve their own program operations and performance. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.
Condition: The Authority paid $388,797 in legal expenses without obtaining approval from HUD. Criteria: Per PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5, a PHA must submit to HUD Regional Counsel for prior written concurrence any litigation service contract where the fee is expected to exceed $100,000 with a private attorney involving a PHA program, project, or activity receiving loan, grant or other subsidy assistance from HUD. Context: During our audit several of the Authority?s legal invoices were selected for testing. During the fiscal year ending March 31, 2022, four checks were issued to the Authority?s legal counsel for a sum total of $388,797. The Authority was not able to provide support for the procurement of these services and could not provide documentation where they obtained HUD approval. Cause: The Authority did not follow the requirements of PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5 and procured a contract for legal services that did not include a not to exceed amount of less than $100,000. Effect: The Authority is not in compliance with HUD rules and regulations. Questioned Costs: $388,797. Auditor Recommendations: The Authority should ensure that it has an understanding and follows all PIH Notices and HUD regulations that are applicable. Management Response: See Corrective Action Plan.
Condition: The Authority did not conduct annual inspections of its Low Rent Public Housing units. Criteria: 24 CFR 5.705 require that the Authority annually inspect its units in accordance with HUD-prescribed physical inspection procedures. Context: As part of our audit of eligibility of the Public and Indian Housing program, the auditor noted that annual inspections were not completed in a timely manner. Cause: Lack of proper oversight contributed to the noncompliance noted. The Authority did not have adequate internal controls in place over failed inspections. Effect: The Authority?s Low Rent Public Housing units may not be decent, safe, sanitary and in good repair. The lack of annual inspections resulted in excessive costs related to unit turnover. Questioned Costs: None. Auditor Recommendations: The Authority should conduct inspections of its Low Rent Public Housing units annually in accordance with HUD requirements to comply with the housing stock being decent, safe, sanitary and in good repair. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.
Condition: The Authority paid $388,797 in legal expenses without obtaining approval from HUD. Criteria: Per PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5, a PHA must submit to HUD Regional Counsel for prior written concurrence any litigation service contract where the fee is expected to exceed $100,000 with a private attorney involving a PHA program, project, or activity receiving loan, grant or other subsidy assistance from HUD. Context: During our audit several of the Authority?s legal invoices were selected for testing. During the fiscal year ending March 31, 2022, four checks were issued to the Authority?s legal counsel for a sum total of $388,797. The Authority was not able to provide support for the procurement of these services and could not provide documentation where they obtained HUD approval. Cause: The Authority did not follow the requirements of PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5 and procured a contract for legal services that did not include a not to exceed amount of less than $100,000. Effect: The Authority is not in compliance with HUD rules and regulations. Questioned Costs: $388,797. Auditor Recommendations: The Authority should ensure that it has an understanding and follows all PIH Notices and HUD regulations that are applicable. Management Response: See Corrective Action Plan.
Condition: The Authority did not conduct annual inspections of its Low Rent Public Housing units. Criteria: 24 CFR 5.705 require that the Authority annually inspect its units in accordance with HUD-prescribed physical inspection procedures. Context: As part of our audit of eligibility of the Public and Indian Housing program, the auditor noted that annual inspections were not completed in a timely manner. Cause: Lack of proper oversight contributed to the noncompliance noted. The Authority did not have adequate internal controls in place over failed inspections. Effect: The Authority?s Low Rent Public Housing units may not be decent, safe, sanitary and in good repair. The lack of annual inspections resulted in excessive costs related to unit turnover. Questioned Costs: None. Auditor Recommendations: The Authority should conduct inspections of its Low Rent Public Housing units annually in accordance with HUD requirements to comply with the housing stock being decent, safe, sanitary and in good repair. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.
(?SEMAP?), it was noted that the Authority lacked the proper documentation and organization to support the self-assessed score that was reported for each indicator, regarding the minimum sample size and the sampling methodology from the correct universe in an unbiased manner. Criteria: 24 CFR 985 requires that the Authority annually submit a SEMAP certification that follows HUD requirements. According to 24 CFR 985.1, SEMAP is designed to determine whether the Section 8 tenant-based assistance programs operate to help eligible families afford decent rental units at the correct subsidy cost. SEMAP provides procedures for HUD to identify PHA management capabilities and deficiencies in order to target monitoring and program assistance more effectively. 24 CFR 985.2 identifies the required minimum sample size for each sub-indicator and requires that the sample is selected in an unbiased manner. Context: The auditor obtained support for the SEMAP submission to test the adequacy of the responses for each indicator. The supporting documentation did not include the correct sample size for several indicators nor did it correctly utilize the information that comes from the Public and Indian Housing Information Center (?PIC?). Cause: Lack of proper oversight and staff training contributed to SEMAP being improperly performed. Effect: The program?s quality control is not being utilized in the most effective manner. The Authority may not be in full compliance with applicable HUD regulations and could receive an inaccurate overall performance rating. Without proper completion of the SEMAP submission, HUD is not able to accurately perform their oversight of the Housing Choice Voucher program. Questioned Costs: None. Auditor Recommendations: The Authority should assign SEMAP responsibilities to a responsible person and provide sufficient training to complete an accurate and complete certification with supporting documentation that meets the requirements of the HUD rules and regulations. The Authority needs to provide the appropriate documentation and support for testing for each of the SEMAP indicators. The Authority should also develop a system to maintain the organization of this documentation which should clearly support the self-assessed scores reported on SEMAP. We recommend SEMAP testing be performed throughout the year and that the Authority use the SEMAP performance analysis to assess and improve their own program operations and performance. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.
(?SEMAP?), it was noted that the Authority lacked the proper documentation and organization to support the self-assessed score that was reported for each indicator, regarding the minimum sample size and the sampling methodology from the correct universe in an unbiased manner. Criteria: 24 CFR 985 requires that the Authority annually submit a SEMAP certification that follows HUD requirements. According to 24 CFR 985.1, SEMAP is designed to determine whether the Section 8 tenant-based assistance programs operate to help eligible families afford decent rental units at the correct subsidy cost. SEMAP provides procedures for HUD to identify PHA management capabilities and deficiencies in order to target monitoring and program assistance more effectively. 24 CFR 985.2 identifies the required minimum sample size for each sub-indicator and requires that the sample is selected in an unbiased manner. Context: The auditor obtained support for the SEMAP submission to test the adequacy of the responses for each indicator. The supporting documentation did not include the correct sample size for several indicators nor did it correctly utilize the information that comes from the Public and Indian Housing Information Center (?PIC?). Cause: Lack of proper oversight and staff training contributed to SEMAP being improperly performed. Effect: The program?s quality control is not being utilized in the most effective manner. The Authority may not be in full compliance with applicable HUD regulations and could receive an inaccurate overall performance rating. Without proper completion of the SEMAP submission, HUD is not able to accurately perform their oversight of the Housing Choice Voucher program. Questioned Costs: None. Auditor Recommendations: The Authority should assign SEMAP responsibilities to a responsible person and provide sufficient training to complete an accurate and complete certification with supporting documentation that meets the requirements of the HUD rules and regulations. The Authority needs to provide the appropriate documentation and support for testing for each of the SEMAP indicators. The Authority should also develop a system to maintain the organization of this documentation which should clearly support the self-assessed scores reported on SEMAP. We recommend SEMAP testing be performed throughout the year and that the Authority use the SEMAP performance analysis to assess and improve their own program operations and performance. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.
Condition: The Authority paid $388,797 in legal expenses without obtaining approval from HUD. Criteria: Per PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5, a PHA must submit to HUD Regional Counsel for prior written concurrence any litigation service contract where the fee is expected to exceed $100,000 with a private attorney involving a PHA program, project, or activity receiving loan, grant or other subsidy assistance from HUD. Context: During our audit several of the Authority?s legal invoices were selected for testing. During the fiscal year ending March 31, 2022, four checks were issued to the Authority?s legal counsel for a sum total of $388,797. The Authority was not able to provide support for the procurement of these services and could not provide documentation where they obtained HUD approval. Cause: The Authority did not follow the requirements of PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5 and procured a contract for legal services that did not include a not to exceed amount of less than $100,000. Effect: The Authority is not in compliance with HUD rules and regulations. Questioned Costs: $388,797. Auditor Recommendations: The Authority should ensure that it has an understanding and follows all PIH Notices and HUD regulations that are applicable. Management Response: See Corrective Action Plan.
Condition: The Authority did not conduct annual inspections of its Low Rent Public Housing units. Criteria: 24 CFR 5.705 require that the Authority annually inspect its units in accordance with HUD-prescribed physical inspection procedures. Context: As part of our audit of eligibility of the Public and Indian Housing program, the auditor noted that annual inspections were not completed in a timely manner. Cause: Lack of proper oversight contributed to the noncompliance noted. The Authority did not have adequate internal controls in place over failed inspections. Effect: The Authority?s Low Rent Public Housing units may not be decent, safe, sanitary and in good repair. The lack of annual inspections resulted in excessive costs related to unit turnover. Questioned Costs: None. Auditor Recommendations: The Authority should conduct inspections of its Low Rent Public Housing units annually in accordance with HUD requirements to comply with the housing stock being decent, safe, sanitary and in good repair. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.
Condition: The Authority paid $388,797 in legal expenses without obtaining approval from HUD. Criteria: Per PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5, a PHA must submit to HUD Regional Counsel for prior written concurrence any litigation service contract where the fee is expected to exceed $100,000 with a private attorney involving a PHA program, project, or activity receiving loan, grant or other subsidy assistance from HUD. Context: During our audit several of the Authority?s legal invoices were selected for testing. During the fiscal year ending March 31, 2022, four checks were issued to the Authority?s legal counsel for a sum total of $388,797. The Authority was not able to provide support for the procurement of these services and could not provide documentation where they obtained HUD approval. Cause: The Authority did not follow the requirements of PIH Notice 2006-9 and the HUD Litigation Handbook 1530.1 REV-5 and procured a contract for legal services that did not include a not to exceed amount of less than $100,000. Effect: The Authority is not in compliance with HUD rules and regulations. Questioned Costs: $388,797. Auditor Recommendations: The Authority should ensure that it has an understanding and follows all PIH Notices and HUD regulations that are applicable. Management Response: See Corrective Action Plan.
Condition: The Authority did not conduct annual inspections of its Low Rent Public Housing units. Criteria: 24 CFR 5.705 require that the Authority annually inspect its units in accordance with HUD-prescribed physical inspection procedures. Context: As part of our audit of eligibility of the Public and Indian Housing program, the auditor noted that annual inspections were not completed in a timely manner. Cause: Lack of proper oversight contributed to the noncompliance noted. The Authority did not have adequate internal controls in place over failed inspections. Effect: The Authority?s Low Rent Public Housing units may not be decent, safe, sanitary and in good repair. The lack of annual inspections resulted in excessive costs related to unit turnover. Questioned Costs: None. Auditor Recommendations: The Authority should conduct inspections of its Low Rent Public Housing units annually in accordance with HUD requirements to comply with the housing stock being decent, safe, sanitary and in good repair. Management Response: See Corrective Action Plan.
Condition: During our audit, we noted multiple disbursements made to vendors who did not have contracts that were properly procured in accordance with the Authority?s policies and HUD rules and regulations. In addition, the procurement files tested only had one quote, which did not follow the Authority?s small purchase procedure. Criteria: The Authority?s procurement policy and HUD rules and regulations require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority. Context: As part of our audit of the Authority?s disbursements, it was noted that multiple checks were issued for services relating to costs associated with unit turnover and HCV inspections. The cumulative annual cost of these services were in excess of the Authority?s procurement policy for small purchases. In addition, legal services were paid to a vendor that were in excess of the Authority?s procurement policy with no supporting documentation of proper procurement provided. Cause: The Authority does not have adequate monitoring controls to identify when payments are made to a vendor that has not been properly procured. Effect: The Authority did not comply with their procurement policies or HUD regulations with regard to the disbursements and contracts in question. Questioned Costs: None. Auditor Recommendations: The Authority should follow its procurement policy regarding small purchase procedures and sealed bids to verify they are in compliance with HUD rules and regulations. In addition, we recommend that the Authority reduce the bidding thresholds in their policy to levels that are more reflective of the amounts that are appropriate for a small agency. Management Response: See Corrective Action Plan.