Audit 56441

SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022-001 ? PROCUREMENT, SUSPENSION, & DEBARMENT Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.850 ? Public and Indian Housing Program CRITERIA For procurements of $10,000 or more, there shall be maintained a written record which includes the contract and any amendments to the contract. If a contract is awarded pursuant to a formal solicitation, the written record shall also include the invitation for bids or request for proposals, the public notices and advertisements, the bids or proposals submitted and written evaluation of proposals. All written documentation required by this Section shall be maintained for a period of six years from the date of final payment under the contract. (Brookline Housing Authority Procurement Policy) CONDITION We examined a sample of 7 vendors used for goods and services during fiscal year 2022, as a result of our procedures, we identified 1 instance in which the Authority did not follow its policy regarding maintaining written documentation for purchases exceeding $10,000. The 1 instance related to frequently recurring transactions that resulted in aggregate purchases exceeding the competitive thresholds. The total payments to the seven vendors aggregated $1,207,503. CAUSE The Authority was in the process of implementing its corrective action plan from the prior year and was not able to review all procurements for vendors with frequently recurring transactions prior to March 31, 2022. EFFECT As a result of not adequately documenting the procurement decision, the Authority has not complied with their procurement policy and cannot ensure that it is receiving the most competitive prices or rates for services that have been procured. QUESTIONED COSTS Estimated questioned costs were less than $25,000. CONTEXT We selected a sample of seven vendors used by the Authority during the year representing aggregate expenditures of $1,207,503. The Authority paid 75 vendors in excess of the micropurchase threshold of $10,000 for the fiscal year. Our sample was not a statistically valid sample. REPEAT FINDING This finding is repeated from finding 2021-001. RECOMMENDATION We recommend that the Authority continue with their corrective action plan from the prior year including: ? Periodically reviewing expenditures for frequently recurring transactions with vendors that could exceed the competitive procurement thresholds. ? Periodically compare the contract register against frequently used vendors. ? Solicit bids and competitively procure contracts for services and materials frequently used and maintain documentation supporting the procurement decision. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022-001 ? PROCUREMENT, SUSPENSION, & DEBARMENT Other Matter/Significant Deficiency U.S. Department of Housing and Urban Development CFDA #: 14.850 ? Public and Indian Housing Program CRITERIA For procurements of $10,000 or more, there shall be maintained a written record which includes the contract and any amendments to the contract. If a contract is awarded pursuant to a formal solicitation, the written record shall also include the invitation for bids or request for proposals, the public notices and advertisements, the bids or proposals submitted and written evaluation of proposals. All written documentation required by this Section shall be maintained for a period of six years from the date of final payment under the contract. (Brookline Housing Authority Procurement Policy) CONDITION We examined a sample of 7 vendors used for goods and services during fiscal year 2022, as a result of our procedures, we identified 1 instance in which the Authority did not follow its policy regarding maintaining written documentation for purchases exceeding $10,000. The 1 instance related to frequently recurring transactions that resulted in aggregate purchases exceeding the competitive thresholds. The total payments to the seven vendors aggregated $1,207,503. CAUSE The Authority was in the process of implementing its corrective action plan from the prior year and was not able to review all procurements for vendors with frequently recurring transactions prior to March 31, 2022. EFFECT As a result of not adequately documenting the procurement decision, the Authority has not complied with their procurement policy and cannot ensure that it is receiving the most competitive prices or rates for services that have been procured. QUESTIONED COSTS Estimated questioned costs were less than $25,000. CONTEXT We selected a sample of seven vendors used by the Authority during the year representing aggregate expenditures of $1,207,503. The Authority paid 75 vendors in excess of the micropurchase threshold of $10,000 for the fiscal year. Our sample was not a statistically valid sample. REPEAT FINDING This finding is repeated from finding 2021-001. RECOMMENDATION We recommend that the Authority continue with their corrective action plan from the prior year including: ? Periodically reviewing expenditures for frequently recurring transactions with vendors that could exceed the competitive procurement thresholds. ? Periodically compare the contract register against frequently used vendors. ? Solicit bids and competitively procure contracts for services and materials frequently used and maintain documentation supporting the procurement decision. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.