Finding 1106390 (2024-001)

United States Department of Housing and Urban Development Passed through from: NYC Housing and Preservation Department Assistance Listing No. 14.267 Continuum of Care Criteria: As required by the 2 CFR section 200.318 through 200.326, nonfederal entities must follow the procurement standards required by that section in accordance with the Uniform Guidance. Condition: The Organization did not adhere to their policy when selecting a vendor to purchase goods at their residential locations. In addition, the procurement policy of the Organization does not align with all requirements under the Uniform Guidance. Cause: The Organization did not bid or procure for purchases of goods at their Euclid and Westbourne locations. Due to familiarity with the vendors, the Organization has been using them for the purchase of these goods and has not adhered to their procurement policy. Effect: The Organization is not adhering to their procurement policy and is not using a bidding process for the purchase of their goods. Context: We selected 4 vendors used that would require procurement procedures to obtain documented price or rate quotations from a number of qualified sources for testing whose purchases totaled approximately $57,000 to $165,000 for the fiscal year. The Organization could not provide us with the required documentation needed to comply with the Uniform Guidance. Recommendation: We recommend that the Organization review and update its procurement policy to align with what is required by the Uniform Guidance and procure all goods, services and material purchases greater than the threshold outlined in the then revised procurement policy and in accordance with Uniform Guidance. Views of Responsible Officials: The Organization has engaged a professional services firm in a consulting engagement to review and assist in revising their procurement policy to align its policies and procedures for procurement with Uniform Guidance.