Finding 1208271 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-04-21
Audit: 399300
Organization: Trilogy, Inc. (IL)

AI Summary

  • Core Issue: The Organization failed to maintain proper documentation for purchases made under the simplified acquisition method.
  • Impacted Requirements: Noncompliance with 2 CFR section 200.320 regarding procurement documentation and record-keeping.
  • Recommended Follow-Up: Ensure adherence to internal policies for documentation and consider qualifying multiple vendors for better procurement practices.

Finding Text

Federal agency: Department of Housing and Urban Development Federal program title: Continuum of Care Program FALN Number: 14.267 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: December 1, 2024 – November 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance Criteria or specific requirement: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require that price or rate quotations be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Furthermore, the Organization's procurement policies require the maintaining of records sufficient to detail the history of procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price Condition: The Organization did not follow the procedures outlined within its internal policies related to maintaining documentation associated with purchases made via the simplified acquisition method of procurement. Questioned costs: $31,673. Context: This condition impacted one (1) of one (1) transaction selected for testing. Cause: Oversight. Effect: The Organization could potentially use federal funds in a manner which is not the most efficient or economical. Repeat Finding: No Recommendation: We recommend the organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Procurement – Assistance Listing No. 14.267 Recommendation: We recommend the organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update its procurement policy to include a formal pre‑approved vendor list and documentation requirements for all procurement methods. Management will standardize procurement files to ensure inclusion of required support, such as vendor selection rationale, cost or price analysis, and approval documentation. Procurement staff will receive training on updated policy requirements, and compliance will be periodically reviewed by management. Name(s) of the contact person(s) responsible for corrective action: Scott Russell Planned completion date for corrective action plan: 6/30/2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1208272 2025-003
    Material Weakness Repeat
  • 1208273 2025-004
    Material Weakness Repeat
  • 1208274 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $1.82M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $300,356
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $260,442
93.150 Projects for Assistance in Transition from Homelessness $199,874
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $158,509
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $134,641