Audit 40938

Federal agency: U.S. Department of Housing and Urban Development Federal program title: Public and Indian Housing Assistance Listing Number: 14.850 Federal Award Identification Number and Year: FL071-00000120D, FL071-00000121D, FL071-00000122D, FL071-00000220D, FL071-00000221D, FL071-00000222D Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Authority should meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. The Entity should conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319 and 200.320. 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. Condition: During the testing of the Public Housing contract files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 1 The Authority did not follow their policy with contracts that had expenses during the fiscal year as they did not go through the procurement process. 1 The Authority did not verify the vendor's eligibility regarding suspension and debarment prior to signing the agreement for services Questioned costs: Undeterminable Context: During our testing, we reviewed the contract, which contained the error noted above. The sample was a statistically valid sample. Cause: The Authority failed to have an updated procurement policy, until an updated was approved on September 20,2022, that adheres to Unform Grant Guidance. Effect: The Authority is out of compliance by not following their procurement policy. Recommendation: We recommend that the Authority update its Procurement Policy from 2009, which was done on September 30, 2022, putting in place the procedures listed in the UG and clarifying procurement methods. As well as, including in the policy that all vendors' eligibility needs to be verified prior to signing contracts, either through SAM or by collecting a certification form from the vendor. Views of responsible officials: There is no disagreement with the finding.

Federal agency: U.S. Department of Housing and Urban Development Federal program title: Public and Indian Housing Assistance Listing Number: 14.850 Federal Award Identification Number and Year: FL071-00000120D, FL071-00000121D, FL071-00000122D, FL071-00000220D, FL071-00000221D, FL071-00000222D Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Authority should meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. The Entity should conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319 and 200.320. 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. Condition: During the testing of the Public Housing contract files, certain eligibility deficiencies were noted as summarized below: Number of Instances Finding 1 The Authority did not follow their policy with contracts that had expenses during the fiscal year as they did not go through the procurement process. 1 The Authority did not verify the vendor's eligibility regarding suspension and debarment prior to signing the agreement for services Questioned costs: Undeterminable Context: During our testing, we reviewed the contract, which contained the error noted above. The sample was a statistically valid sample. Cause: The Authority failed to have an updated procurement policy, until an updated was approved on September 20,2022, that adheres to Unform Grant Guidance. Effect: The Authority is out of compliance by not following their procurement policy. Recommendation: We recommend that the Authority update its Procurement Policy from 2009, which was done on September 30, 2022, putting in place the procedures listed in the UG and clarifying procurement methods. As well as, including in the policy that all vendors' eligibility needs to be verified prior to signing contracts, either through SAM or by collecting a certification form from the vendor. Views of responsible officials: There is no disagreement with the finding.