Finding Text
2023-003 Procurement Material Weakness This is a repeat finding. The prior-year’s auditing finding number is 2022-003. Condition: Out of 9 procurements selected for testing 9 did not have an adequate number of bids/quotes documented or an allowable sole source justification documented. Criteria: Part III. Procurement Methods of the Housing Authority’s procurement policy states that “When satisfying its needs by procurement, the St. Croix Chippewa Housing Authority shall choose one of the following procurement methods, based on the nature and anticipated dollar value of the total requirement. The St. Croix Chippewa Housing Authority shall provide a rational in its supporting documentation as to why it selected that particular method...a. Quotes may be obtained orally (either in person or by telephone), by catalog, fax, email or supplier/vendor website. b. If the purchase is made for reasons other than price, the file must clearly describe the reason for the purchase.” Section 200.320 Methods of Procurement to be Followed of the Office of Management and Budget’s Uniform Guidance outlines the following requirements: • Price or rate quotations must be obtained from an adequate number of qualified sources if the procurement exceeds the small purchase threshold ($3,000). • Formal bidding procedures must be used if the procurement exceeds the Simplified Acquisition Threshold ($150,000). • Sole sourcing is only allowed when one or more of the following circumstances apply: (1) The item is available only from a single source; (2) The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; (3) The federal agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-federal entity; or (4) After solicitation of a number of sources, competition is determined inadequate. Cause: Adopted policies do not reflect the requirements outlined in the OMB Uniform Guidance. Effect: The Housing Authority may be paying too much for goods and services. Recommendation: Update and implement policies that agree with OMB Uniform Guidance. Views of Responsible Officials: See Corrective Action Plan.