Audit 358620

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Compass Technical Assistance and Capacity Building Assistance Listing Number: 14.259 Federal Award Identification Number and Year: N-15-IT-TA-0001 Award Period: 03/17/16-09/12/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: UG §200.318 General Procurement Standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: For one of the eight procured vendors selected for testing, NAIHC did not retain a signed contract between the vendor and NAIHC. Context: A nonstatistical sample of eight out of thirty-seven procured vendors were selected for testing for the Community Compass Technical Assistance and Capacity Building program. The condition noted above was identified during our procedures over the Procurement compliance requirements. Effect: NAIHC did not properly retain required documentation of procurement details. Cause: NAIHC did not retain a signed contract. Recommendation: We recommend that NAIHC strengthen its current policies and procedures to ensure that a signed contract is retained with procurement documentation. Management’s View: See Separate Corrective Action Plan.

2023-08 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Compass Technical Assistance and Capacity Building Assistance Listing Number: 14.259 Federal Award Identification Number and Year: N-15-IT-TA-0001, Year 2016 Award Period: 03/17/16-09/12/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: For one of the six procured vendors selected for testing, NAIHC did not verify suspension and debarment status of one vendor prior to contracting the vendor. Context: A nonstatistical sample of six out of twenty procured vendors were selected for testing for the Community Compass Technical Assistance and Capacity Building program. The condition noted above was identified during our procedures over the Procurement compliance requirements. Effect: NAIHC contracted with a vendor without verifying suspension and debarment status. Cause: NAIHC did not verify suspension and debarment status. Recommendation: We recommend that NAIHC strengthen its current policies and procedures to ensure that evidence of verifying suspension and debarment status is retained. Management’s View: See Separate Corrective Action Plan.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Compass Technical Assistance and Capacity Building Assistance Listing Number: 14.259 Federal Award Identification Number and Year: N-15-IT-TA-0001 Award Period: 03/17/16-09/12/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: UG §200.318 General Procurement Standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: For one of the eight procured vendors selected for testing, NAIHC did not retain a signed contract between the vendor and NAIHC. Context: A nonstatistical sample of eight out of thirty-seven procured vendors were selected for testing for the Community Compass Technical Assistance and Capacity Building program. The condition noted above was identified during our procedures over the Procurement compliance requirements. Effect: NAIHC did not properly retain required documentation of procurement details. Cause: NAIHC did not retain a signed contract. Recommendation: We recommend that NAIHC strengthen its current policies and procedures to ensure that a signed contract is retained with procurement documentation. Management’s View: See Separate Corrective Action Plan.

2023-08 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Compass Technical Assistance and Capacity Building Assistance Listing Number: 14.259 Federal Award Identification Number and Year: N-15-IT-TA-0001, Year 2016 Award Period: 03/17/16-09/12/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: For one of the six procured vendors selected for testing, NAIHC did not verify suspension and debarment status of one vendor prior to contracting the vendor. Context: A nonstatistical sample of six out of twenty procured vendors were selected for testing for the Community Compass Technical Assistance and Capacity Building program. The condition noted above was identified during our procedures over the Procurement compliance requirements. Effect: NAIHC contracted with a vendor without verifying suspension and debarment status. Cause: NAIHC did not verify suspension and debarment status. Recommendation: We recommend that NAIHC strengthen its current policies and procedures to ensure that evidence of verifying suspension and debarment status is retained. Management’s View: See Separate Corrective Action Plan.