Finding 1172088 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-02-03

AI Summary

  • Core Issue: Five out of seven contracts lacked proper documentation, making it unclear if they were procured according to HUD requirements.
  • Impacted Requirements: The Authority failed to meet procurement standards set by HUD and 2 CFR 200.318, which require thorough documentation and fair competition.
  • Recommended Follow-Up: Implement standardized procurement procedures, including checklists and training for staff, to improve compliance and documentation retention.

Finding Text

Condition: For five of the seven contracts tested, the Authority was unable to provide adequate documentation to demonstrate that the contracts were properly procured. Missing documentation included Notice of Solicitation, contract proposals, Certification of Bidders, and documentation of evaluation or a bid listing with amounts. As a result, we were unable to determine whether the contracts were awarded in accordance with HUD procurement requirements. Context: The auditor haphazardly selected 7 contract files out of the population of 17 contracts procured during the year end September 30, 2024, which we consider to be a statistically valid sample. As part of our audit procedures, we reviewed procurement files to assess areas of compliance with HUD requirements and the effectiveness of internal controls over procurement activities. Criteria: The Authority’s procurement policy, HUD rules and regulations, and 2 CFR 200.318 require that certain procedures be performed in the procurement of vendors to ensure that fair and open competition results in services of the best possible value to the Authority, and that sufficient documentation be maintained to support the procurement method selected for the contract award process. Cause: The Authority experienced staffing and operational changes during and subsequent to the year ended September 30, 2024. Due to staffing changes and ineffective controls over the procurement process, the Authority was unable to ensure procurement requirements were consistently followed and that proper documentation was retained. Effect: As a result of the lack of adequate procurement documentation, the Authority is unable to demonstrate that contracts were awarded in compliance with the Authority’s and HUD’s procurement requirements. Questioned Costs: $343,477. Auditor’s Recommendations: The Authority should strengthen their internal controls over procurement by implementing standardized procurement procedures, including documentation checklists and supervisory review processes to ensure compliance with procurement requirements. The Authority should also provide training to staff involved in the process to ensure they are aware of the requirements and processes. Management Response: See Corrective Action Plan.

Corrective Action Plan

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in procurement. We accept responsibility for the deficiencies in internal control over procurement and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. • Implement Standardized Procurement Procedures: Update and implement a forma', written procurement policy that clearly outlines the procedures for sealed bids, proposals, and small purchases. • Mandatory Documentation Checklist: Create a procurement file checklist for every contract to ensure all required documents—such as the independent cost estimate, advertisement, bidder list, evaluations, and justification for award—are included in the procurement file. • Supervisory Review Process: A supervisor will review and sign off on the procurement file checklist before a contract is executed. • Staff Training: Provide comprehensive training to all staff involved in procurement to ensure they understand H U D's procurement standards, including requirements forf ull and open competition and proper record-keeping. • Maintain Records: Ensure that all documentation for the full procurement cycle is maintained, including evidence that contractors are not debarred or suspended. Name of Responsible Person: Catherine Lamberg, CEO and Jackie Otto, COO, and Natalie Hawks, Procurement Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by May 1, 2026.

Categories

Procurement, Suspension & Debarment HUD Housing Programs

Other Findings in this Audit

  • 1172072 2024-002
    Material Weakness Repeat
  • 1172073 2024-003
    Material Weakness Repeat
  • 1172074 2024-004
    Material Weakness Repeat
  • 1172075 2024-005
    Material Weakness Repeat
  • 1172076 2024-006
    Material Weakness Repeat
  • 1172077 2024-002
    Material Weakness Repeat
  • 1172078 2024-003
    Material Weakness Repeat
  • 1172079 2024-004
    Material Weakness Repeat
  • 1172080 2024-005
    Material Weakness Repeat
  • 1172081 2024-006
    Material Weakness Repeat
  • 1172082 2024-002
    Material Weakness Repeat
  • 1172083 2024-003
    Material Weakness Repeat
  • 1172084 2024-004
    Material Weakness Repeat
  • 1172085 2024-005
    Material Weakness Repeat
  • 1172086 2024-006
    Material Weakness Repeat
  • 1172087 2024-002
    Material Weakness Repeat
  • 1172089 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.872 PUBLIC HOUSING CAPITAL FUND $847,209
14.850 PUBLIC HOUSING OPERATING FUND $533,477
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $270,152
14.879 MAINSTREAM VOUCHERS $252,031