Finding 1174704 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-02-20

AI Summary

  • Core Issue: The Agency failed to maintain proper documentation for its procurement processes, specifically for sole source procurement.
  • Impacted Requirements: This deficiency violates the Uniform Guidance, which mandates documentation to justify procurement methods.
  • Recommended Follow-Up: Implement an electronic system to ensure an audit trail for all procurements is maintained moving forward.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL178L5T172302 - 2024 IL0315L5T142316 - 2024 IL1651L5Y142305 - 2024 IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL0315LST142215 – 2023 Award Periods: August 1, 2023 – July 31, 2024; August 1, 2024 – July 31, 2025; July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Under the Uniform Guidance, organizations are required to document the basis for their procurement. For the procurements tested, the Agency did not have documentation to support how these procurements met the requirements. Condition: While the Agency has a procurement policy in place that meets the requirements of Uniform Guidance, the Agency did not create and retain appropriate documentation for the method of procurement utilized. Questioned Costs: None Context: For one transaction selected for testing under assistance listing number (ALN) 14.267 the Agency utilized the sole source method of procurement but did not maintain documentation justifying why the use of this method was appropriate. Cause: Unknown Effect: Lack of following procurement procedures could result in the Agency engaging vendors who are not the most efficient or economical. Repeat Finding: This finding is a repeat of finding 2024-001. Recommendation: CLA recommends the Agency maintain an audit trail for all procurements. This can be done electronically for efficiency. Views of Responsible Officials: There is no disagreement with this audit finding.

Corrective Action Plan

Recommendation: CLA recommends the Agency maintain an audit trail for all procurements. This can be done electronically for efficiency. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for the maintenance of documentation related to procurement determinations. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 1174705 2025-002
    Material Weakness Repeat
  • 1174706 2025-003
    Material Weakness Repeat
  • 1174707 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $910,465
14.261 NATIONAL HOMELESS DATA ANALYSIS PROJECT (NHDAP) $476,346
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $361,616
93.667 SOCIAL SERVICES BLOCK GRANT $226,489
93.276 DRUG-FREE COMMUNITIES SUPPORT PROGRAM GRANTS $98,826
93.569 COMMUNITY SERVICES BLOCK GRANT $18,912