The Brookline Housing Authority (BHA) takes seriously all audit deficiencies. Immediate corrective action has and will be taken after Marcum LLP notified the BHA of this issue during the FY ?22 audit process. Specific details of how the BHA intends to address this finding are detailed below. 2022-00...
The Brookline Housing Authority (BHA) takes seriously all audit deficiencies. Immediate corrective action has and will be taken after Marcum LLP notified the BHA of this issue during the FY ?22 audit process. Specific details of how the BHA intends to address this finding are detailed below. 2022-001 ? Procurement, Suspension & Debarment 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) 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. Auditee?s Response and Planned Corrective Action The BHA made strides during FY 2022 and strives to continue to prioritize contract and procurement practices that comply with applicable state (M.G.L 30B) and federal regulations. There was one issue, with one particular vendor that gave rise to this finding. The BHA Board of Commissioners approved an updated procurement policy as recommended by the Executive Director in the 1st quarter of FY 2022. This policy is compliant with both state and federal procurement guidelines but also contains additional controls on spending thresholds to ensure competitive contracting beyond regulatory requirements. The BHA already maintained records for six or more years from the date of final procurement for procurements $10,000 or larger. However, it did not have consistent record retention of small vendors that were used repeatedly under this $10,000 threshold and where bids could be solicited without an RFP. Going forward these records will be retained for repeatedly used vendors. The Director of Maintenance and Modernization has already been systematically re-procuring trades like electrical and painting in late FY 2022 and throughout FY 2023 where this was an issue and within a calendar year should fully re-procure all applicable services. The BHA is also planning to make the following immediate corrective actions and changes to internal controls: 1. The Director of Operations and Director of Maintenance and Modernization have both become certified Procurement Officers for the Brookline Housing Authority. 2. The Director of Operations, Director of Finance, and Executive Director will periodically review expenditures for frequently recurring transactions that could exceed competitive procurement thresholds. 3. The Director of Operations, Director of Finance, and Executive Director will periodically compare the contract register against frequently used vendors. 4. The BHA already retains a contract register and procurement details for competitive procurements over $10,000. The BHA will require all staff to retain solicitation records and materials used to make a procurement decision for smaller contracts and enter recurring contractors into the contract log. Planned Implementation Date of Corrective Action: November 28, 2022. Persons Responsible for Corrective Action: Michael Alperin, Executive Director, Lisa Brown, Director of Operations, Chris Devoll, Director of Maintenance and Modernization and John Kelley, Director of Finance. (617)-277-2022