Finding 1182346 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-24
Audit: 393787
Auditor: CLARK NUBER P S

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance with procurement procedures as required by 2 CFR Part 200.
  • Impacted Requirements: The Organization failed to maintain adequate documentation for procurement transactions, violating federal standards for procurement policies.
  • Recommended Follow-Up: Strengthen internal controls to ensure proper documentation is prepared, retained, and reviewed according to the written procurement policy and Uniform Guidance.

Finding Text

Finding 2025-002 Significant deficiency in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Identification of the Federal Program Federal Agency: The United States Department of Housing and Urban Development Program Title: Continuum of Care Program Assistance Listing Number: 14.267 Award Numbers: All Award Periods: All Criteria Requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D – Post Federal Award Requirements, Sections 200.318 through 200.326, require that a nonfederal entity establish and follow a written procurement policy that conforms to federal standards. The Uniform Guidance further requires that procurement transactions be documented in sufficient detail to provide a complete history of the procurement, including the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price (2 CFR 200.318(i), 200.319, and related sections). The written procurement policy must identify formal and informal procurement actions to be taken based on the size of the procurement, covering both goods and services, and must require documentation to support compliance with those requirements. Condition The Organization did not maintain adequate procurement documentation to support procurement transactions. For four out of nine of the items tested, the Organization could not provide documentation sufficient to evidence the method of procurement and that adequate price quotes were received in accordance with the Organizations documented procurement policy. Cause The Organization’s internal controls were insufficient to ensure that required procurement documentation was prepared, retained, and reviewed in accordance with its written procurement policy and Uniform Guidance requirements. Questioned Costs Not applicable. Effect The Organization did not retain documentation sufficient to comply the procurement standards set out at 2 CFR Part 200 as it related to the selected procurement transactions. Repeat Finding No

Corrective Action Plan

Finding 2025-002 Significant deficiency in internal control over compliance with procurement procedures meeting the requirements of 2 CFR Part 200. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: Management will revise the organization's procurement policy to amend the current dollar threshold, which was determined to be overly restrictive and inconsistent with operational needs and federal procurement standards under 2 CFR Part 200. The updated threshold will align with the Uniform Guidance requirements and provide clear guidance for competitive procurement processes. In addition, the organization will implement a standardized Vendor Justification Form. This form will be required for applicable purchases and will document the rationale for vendor selection, including the price analysis, sole source justification (if applicable), and confirmation that the procurement procedures were followed in accordance with federal requirements. These corrective actions are intended to strengthen internal controls over procurement, improve documentation consistency, and ensure compliance with 2 CFR 200 requirements. Anticipated completion date: August 31, 2026

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 1182333 2025-001
    Material Weakness Repeat
  • 1182334 2025-001
    Material Weakness Repeat
  • 1182335 2025-001
    Material Weakness Repeat
  • 1182336 2025-001
    Material Weakness Repeat
  • 1182337 2025-001
    Material Weakness Repeat
  • 1182338 2025-001
    Material Weakness Repeat
  • 1182339 2025-001
    Material Weakness Repeat
  • 1182340 2025-002
    Material Weakness Repeat
  • 1182341 2025-003
    Material Weakness Repeat
  • 1182342 2025-001
    Material Weakness Repeat
  • 1182343 2025-002
    Material Weakness Repeat
  • 1182344 2025-003
    Material Weakness Repeat
  • 1182345 2025-001
    Material Weakness Repeat
  • 1182347 2025-003
    Material Weakness Repeat
  • 1182348 2025-001
    Material Weakness Repeat
  • 1182349 2025-001
    Material Weakness Repeat
  • 1182350 2025-001
    Material Weakness Repeat
  • 1182351 2025-001
    Material Weakness Repeat
  • 1182352 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $1.44M
94.016 AMERICORPS SENIORS SENIOR COMPANION PROGRAM (SCP) 94.016 $216,464
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $204,684
14.267 CONTINUUM OF CARE PROGRAM $185,636
93.676 UNACCOMPANIED CHILDREN PROGRAM $178,914
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $177,493
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $174,184
94.002 AMERICORPS SENIORS RETIRED AND SENIOR VOLUNTEER PROGRAM (RSVP) 94.002 $134,723
97.010 CITIZENSHIP EDUCATION AND TRAINING $105,366
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $101,381
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $100,672
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $98,239
14.276 YOUTH HOMELESSNESS DEMONSTRATION PROGRAM $83,718
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $74,737
16.575 CRIME VICTIM ASSISTANCE $62,105
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $61,457
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $47,695
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $38,252
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $32,015
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $30,000
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $19,155
93.667 SOCIAL SERVICES BLOCK GRANT $13,246
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $9,943
16.736 TRANSITIONAL HOUSING ASSISTANCE FOR VICTIMS OF DOMESTIC VIOLENCE, DATING VIOLENCE, STALKING, OR SEXUAL ASSAULT $1,544