2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-004 – Absence of Prevailing Wage Rate Clauses in Contract – Significant Deficiency in
Internal Controls over Compliance and Noncompliance
Federal Program Information
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – During the review of the contract for the Housing Authority’s HVAC project, it was
noted that the contract did not include clauses mandating the payment of prevailing wage rates to
workers.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Per Title 2 US Code of Federal Regulations Appendix II to Part 200, contracts for construction
funded by Federal awards in excess of $2,000 must contain provisions incorporating the Davis-
Bacon Act, which requires contractors and subcontractors to pay prevailing wages for the work
performed under the contract.
Questioned Costs – None.
Effect – The absence of these clauses may result in non-compliance with federal or state labor laws,
potentially leading to legal penalties, financial liabilities, and reputational damage for the City.
Additionally, workers may not receive fair compensation for their labor.
Cause – The omission of prevailing wage rate clauses appears to be due to an oversight by the
Housing Authority personnel during the contract drafting and approval process.
2023-004 – Absence of Prevailing Wage Rate Clauses in Contract – Significant Deficiency in
Internal Controls over Compliance and Noncompliance
Federal Program Information
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – During the review of the contract for the Housing Authority’s HVAC project, it was
noted that the contract did not include clauses mandating the payment of prevailing wage rates to
workers.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Per Title 2 US Code of Federal Regulations Appendix II to Part 200, contracts for construction
funded by Federal awards in excess of $2,000 must contain provisions incorporating the Davis-
Bacon Act, which requires contractors and subcontractors to pay prevailing wages for the work
performed under the contract.
Questioned Costs – None.
Effect – The absence of these clauses may result in non-compliance with federal or state labor laws,
potentially leading to legal penalties, financial liabilities, and reputational damage for the City.
Additionally, workers may not receive fair compensation for their labor.
Cause – The omission of prevailing wage rate clauses appears to be due to an oversight by the
Housing Authority personnel during the contract drafting and approval process.
2023-004 – Absence of Prevailing Wage Rate Clauses in Contract – Significant Deficiency in
Internal Controls over Compliance and Noncompliance
Federal Program Information
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – During the review of the contract for the Housing Authority’s HVAC project, it was
noted that the contract did not include clauses mandating the payment of prevailing wage rates to
workers.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Per Title 2 US Code of Federal Regulations Appendix II to Part 200, contracts for construction
funded by Federal awards in excess of $2,000 must contain provisions incorporating the Davis-
Bacon Act, which requires contractors and subcontractors to pay prevailing wages for the work
performed under the contract.
Questioned Costs – None.
Effect – The absence of these clauses may result in non-compliance with federal or state labor laws,
potentially leading to legal penalties, financial liabilities, and reputational damage for the City.
Additionally, workers may not receive fair compensation for their labor.
Cause – The omission of prevailing wage rate clauses appears to be due to an oversight by the
Housing Authority personnel during the contract drafting and approval process.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-004 – Absence of Prevailing Wage Rate Clauses in Contract – Significant Deficiency in
Internal Controls over Compliance and Noncompliance
Federal Program Information
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – During the review of the contract for the Housing Authority’s HVAC project, it was
noted that the contract did not include clauses mandating the payment of prevailing wage rates to
workers.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Per Title 2 US Code of Federal Regulations Appendix II to Part 200, contracts for construction
funded by Federal awards in excess of $2,000 must contain provisions incorporating the Davis-
Bacon Act, which requires contractors and subcontractors to pay prevailing wages for the work
performed under the contract.
Questioned Costs – None.
Effect – The absence of these clauses may result in non-compliance with federal or state labor laws,
potentially leading to legal penalties, financial liabilities, and reputational damage for the City.
Additionally, workers may not receive fair compensation for their labor.
Cause – The omission of prevailing wage rate clauses appears to be due to an oversight by the
Housing Authority personnel during the contract drafting and approval process.
2023-004 – Absence of Prevailing Wage Rate Clauses in Contract – Significant Deficiency in
Internal Controls over Compliance and Noncompliance
Federal Program Information
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – During the review of the contract for the Housing Authority’s HVAC project, it was
noted that the contract did not include clauses mandating the payment of prevailing wage rates to
workers.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Per Title 2 US Code of Federal Regulations Appendix II to Part 200, contracts for construction
funded by Federal awards in excess of $2,000 must contain provisions incorporating the Davis-
Bacon Act, which requires contractors and subcontractors to pay prevailing wages for the work
performed under the contract.
Questioned Costs – None.
Effect – The absence of these clauses may result in non-compliance with federal or state labor laws,
potentially leading to legal penalties, financial liabilities, and reputational damage for the City.
Additionally, workers may not receive fair compensation for their labor.
Cause – The omission of prevailing wage rate clauses appears to be due to an oversight by the
Housing Authority personnel during the contract drafting and approval process.
2023-004 – Absence of Prevailing Wage Rate Clauses in Contract – Significant Deficiency in
Internal Controls over Compliance and Noncompliance
Federal Program Information
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – During the review of the contract for the Housing Authority’s HVAC project, it was
noted that the contract did not include clauses mandating the payment of prevailing wage rates to
workers.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Per Title 2 US Code of Federal Regulations Appendix II to Part 200, contracts for construction
funded by Federal awards in excess of $2,000 must contain provisions incorporating the Davis-
Bacon Act, which requires contractors and subcontractors to pay prevailing wages for the work
performed under the contract.
Questioned Costs – None.
Effect – The absence of these clauses may result in non-compliance with federal or state labor laws,
potentially leading to legal penalties, financial liabilities, and reputational damage for the City.
Additionally, workers may not receive fair compensation for their labor.
Cause – The omission of prevailing wage rate clauses appears to be due to an oversight by the
Housing Authority personnel during the contract drafting and approval process.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.
2023-003 (2022-001) – Procurement Policy and Suspension and Debarment Verification
Procedures – Significant Deficiency in Internal Controls over Compliance and Questioned Costs
>$25,000 and Noncompliance
Federal Program Information
Federal Award Title and ALN: 21.027 Coronavirus State and Local Fiscal Recovery Fund
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: SLFRP0125
Federal Award Year: 2023
Federal Award Title and ALN: 14.872 Public Housing Capital Fund
Federal Awarding Agency: U.S. Department of Housing and Urban Development
Federal Award ID Number: FW-5439; FW-5436; FW-5438
Federal Award Year: 2023
Condition – The City's procurement policy requires quotes for procurements in excess of $20,000,
whereas the Uniform Guidance sets the threshold at the micro-purchase threshold of $10,000.
$26,785 in procurements between $10,000 and $20,000 were not quoted prior to purchase. The
City is not checking vendors for suspension and debarment prior to using.
The City had been working on updating their policies and procedures during fiscal year 2024 to
comply with federal procurement requirements. The City is also working on changing their
processes to ensure compliance.
Criteria – Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must
establish and maintain effective internal control over Federal awards that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. For suspension and debarment, 2 CFR 180 subpart C requires checking SAM exclusions, collecting a
certification, or adding a clause or condition to contract documents before entering into a covered
transaction with another party.
Questioned Costs – Known and likely questioned costs of $26,785 - ALN 21.027
Effect – Engaging vendors without verifying their suspension and debarment status increases the
risk of contracting with ineligible vendors, which could lead to financial losses, legal liabilities, and
potential disqualification from future federal funding.
Cause – The lack of verification was due to inadequate internal controls and oversight within the
procurement department. There was no established procedure or checklist to ensure compliance
with suspension and debarment verification requirements.