Finding 1162124 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2025
Accepted
2025-11-07
Audit: 371931
Organization: Barre Housing Authority (VT)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: The Barre Housing Authority failed to follow its own procurement policy, leading to improper vendor selection for 8 contracts.
  • Impacted Requirements: Purchases over $10,000 must follow competitive bidding procedures to ensure fair pricing and compliance with regulations.
  • Recommended Follow-up: Develop and implement stronger policies to ensure adherence to procurement guidelines and avoid repeat findings.

Finding Text

2025-001 – PROCUREMENTS, SUSPENSION AND DEBARMENT Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.850 – Public and Indian Housing CRITERIA Any small purchase or contract, greater than $10,000 ($2,000 if Davis-Bacon rules apply) but not exceeding $50,000, may be made in accordance with the small purchase procedures outlined in this section. BHA staff seeking prospective purchase, to be funded within the current year’s operating or capital budget they manage should solicit a minimum of two price quotes, oral or written, if available from prospective contractors, through a competitive Request for Proposal (RFP) process by phone, fax or email. Results of this process, including bid selection recommendation and related justification are then presented to the compliance officer who will make the award to the entity with the lowest acceptable bid and/or greatest value. CONDITION We identified 8 instances in which vendors were not properly procured in accordance with the Barre Housing Authority’s Procurement Policy. CAUSE The Barre Housing Authority’s Procurement Policy was not properly implemented. 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 - $469,860 representing the aggregate payments to these 8 vendors. CONTEXT All purchases are required to be made in accordance with the Authority’s procurement policy. There were 8 vendors paid in excess of the micro purchase threshold. We selected all 8 vendors. REPEAT FINDING See Finding 2024-001 RECOMMENDATION We recommend that the Authority develop and implement sufficient policies and procedures which provide assurance for compliance with the Procurement, Suspension, and Debarment requirements of the Uniform Guidance. AUDITEE’S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

Finding 2025-001 - Procurements, Suspension and Debarment Corrective Action Plan Policy Review and Revision: The Executive Director will conduct a comprehensive review of the existing Procurement Policy to identify areas that can be clarified, simplified, or strengthened to ensure full compliance with HUD procurement regulations and Uniform Guidance (2 CFR Part 200). Any revisions will be presented to the Board of Commissioners for approval and adopted by the Authority. Staff Training on Procurement Requirements: The Executive Director, Jaime Chioldi, will identify and complete specialized training in federal procurement requirements specific to public housing authorities. The Director of Maintenance, Brian Calderara, will also complete this training. Documentation of training completion will be maintained in personnel files. Training will be with either Nan Mckay or NAHRO. Enhanced Oversight and Monitoring: Because the majority of procurement issues occurred within maintenance operations, the Executive Director will implement additional oversight measures for the Maintenance Department's purchasing activities. Monthly procurement reports will be generated to monitor cumulative vendor spending. The reports will be reviewed to identify when aggregate totals approach procurement threshold limits described in the policy. Any purchases nearing the small purchase or competitive bid limits will be reviewed and approved by the Executive Director before commitment. Documentation and Compliance Verification: The Authority will maintain complete procurement documentation for all purchases above the micro-purchase threshold, including quotes, justification, and vendor selection criteria. A quarterly internal review will be conducted to verify adherence to policy and identify any corrective needs. Responsible Official Jaime L. Chioldi, Executive Director Barre Housing Authority Email: jaime@barrehousing.org Phone: 802-476-7224 Anticipated Completion Date All corrective actions will be fully implemented by March 31, 2026.

Categories

Questioned Costs Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
14.850 PUBLIC HOUSING OPERATING FUND $1.59M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $1.03M
14.872 PUBLIC HOUSING CAPITAL FUND $939,360