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2024 -004 – PROCUREMENT, SUSPENSION, AND DEBARMENT Significant Deficiency / Other Matter U.S. Department of Housing and Urban Development ALN #: 14.850 – Public Housing Operating Fund CRITERIA For any amounts above the Petty Cash ceiling, but not exceeding $250,000 in accordance with revisions to 2CFR 200.67 and 2 CFR 200.88, the NBHA may use small purchase procedures. Under small purchase procedures, the NBHA shall obtain a reasonable number of quotes (preferably three); however, for purchases of less than $10,000, per NDAA Section 806 also known as Micro Purchases, only one quote is required provided the quote is reasonable. CONDITION We identified 4 instances in which sufficient documentation was not maintained to support the procurement of a vendor. CAUSE The Authority was in the process of implementing their corrective action plan from the prior year. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Known Questioned Costs - $246,133, representing the aggregate payments to these four vendors. CONTEXT All purchases are required to be made in accordance with the Authority’s procurement policy. There were approximately 60 vendors paid in excess of the micro purchase threshold. We selected a sample of 10 vendors. This was not a statistically valid sample. REPEAT FINDING Repeated from Finding 2023-003. RECOMMENDATION We recommend that the Authority continue with their corrective action plan from the prior year. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.