Audit 396845

2025-002 – Waiting List Procedures U.S. Department of Housing and Urban Development 14.850 – Public Housing Operating Fund N. Special Tests and Provisions - Public Housing Waiting List - Significant Deficiency - Internal Control and Compliance Finding Condition: During review of the Public Housing Operating Fund program, RBT noted the Authority did not retain sufficient documentation demonstrating that newly admitted tenants were selected from the waiting list in accordance with its established waiting list policy. Criteria: The PHA must establish and adopt written policies for admitting tenants. The PHA tenant selection policies must include requirements for applications and waiting lists, a description of the policies for selecting applicants from the waiting lists, and policies for verification and documentation of information relevant to the acceptance or rejection of an applicant (24 CFR sections 960.202 through 960.206). Cause: The Authority’s internal controls over the waiting list selection process were not adequately designed or implemented to ensure documentation was retained in accordance with the Authority’s policy. Effect: Potential loss of funding due to noncompliance or additional noncompliance if a control is missed. Questioned Costs: None identified. Perspective: The newly admitted tenant to the program selected for testing did not contain an audit trail or supporting documentation demonstrating when the tenant was added to the waiting list or how their selection was determined based on points or ranking. Repeat Finding: Not a repeat finding. Recommendation: RBT recommends the Authority implement internal controls to ensure that documentation is maintained to support the selection of newly admitted tenants from the waiting list. Such documentation should include the date the applicant was added to the waiting list, their ranking determination, and evidence that selection was made in accordance with the Authority’s established waiting list policy. Auditee's Response: See corrective action plan.

2025-003 – Suspension and Debarment U.S. Department of Housing and Urban Development 14.850 – Public Housing Operating Fund I. Procurement and Suspension and Debarment – Significant Deficiency - Internal Control Condition: During review of the Public Housing Operating Fund program, RBT noted the Authority did not document verification that vendors were not suspended or debarred from participating in federally funded programs. The Authority was unable to provide evidence that suspension and debarment checks were conducted prior to contract award or payment. Criteria: Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under non-procurement transactions that are expected to equal or exceed $25,000, or meet certain criteria as specified in 2 CFR 180.220. 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 180.995 and by the agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transactions. 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 SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300). Cause: The Authority does not have a central, uniform location to document the controls in place for documenting practices related to suspension and debarment verification during the procurement process. Effect: Failure to verify and document suspension and debarment status increases the risk that the Authority could enter into contracts with ineligible vendors, resulting in potential noncompliance with federal procurement requirements. Questioned Costs: None identified. Perspective: None of the twenty-five purchases selected for testing contained documentation demonstrating that vendor verification procedures over suspension and debarment were performed. Repeat Finding: Not a repeat finding. Recommendation: RBT recommends the Authority implement procedures to formally document its review of the federal and state suspension and debarment lists for applicable vendors. Documentation of the verification, such as a screenshot or record of the search in the System for Award Management (SAM.gov), should be retained in the procurement file to demonstrate compliance with federal regulations. Auditee's Response: See corrective action plan.