Finding 1228502 (2025-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-08-31

AI Summary

  • Core Issue: The Housing Authority failed to comply with procurement policies and federal requirements for purchases over $40,000, leading to potential misuse of funds.
  • Impacted Requirements: Noncompliance with 2 CFR 200 standards for full and open competition and the Authority's own procurement policy.
  • Recommended Follow-Up: Strengthen procurement procedures, ensure proper documentation and approvals, and provide training for staff on procurement requirements.

Finding Text

Finding 2025-004 – Procurement Deficiencies – Procurement and Suspension and Debarment – ALN 14.850 Low Rent Public Housing, ALN 14.872 Capital Fund Program – Noncompliance and Material Weakness Condition & Cause: We reviewed a sample of three vendor contracts and payments over the Housing Authority’s $40,000 small purchase threshold. For two large purchases, we have determined that the Housing Authority has not shown compliance with its procurement policy or federal procurement requirements. • The Authority purchased three vehicles from Gary Yeomans Ford for a total of $127,434. We found no evidence that the purchases were solicited or advertised, no documentation that other vehicle suppliers were solicited or considered, and no sole-source justification on file supporting a noncompetitive procurement. • The Authority paid Epp-lectric $214,269 for a metering project. This was documented and procured as a small purchase (three quotes obtained) instead of a formal sealed bid, even though the dollar amount required formal bidding. The deficiencies can be attributed to a lack of oversight over procurement during the audit period. Criteria: Procurement Standards outlined in 2 CFR 200 require full and open competition once purchases exceed an entity’s small purchase threshold and lay out specific methods for meeting that requirement. The Authority’s own policy sets that threshold at $40,000. Effect: Without proper competition and documentation, the Authority can’t show these purchases were reasonable or the best use of federal funds. Recommendation: The Authority should strengthen its procurement procedures to ensure staff use the correct method and require documented review and approval before a purchase is made. All parties involved with procurement should also receive training in procurement requirements. Questioned Costs: None Repeat Finding: No Was sampling statistically valid? Yes Views of responsible officials: The PHA agrees with the results of the audit and recommendations.

Corrective Action Plan

Finding 2025-004 – Procurement Deficiencies – Procurement and Suspension and Debarment – ALN 14.850 Low Rent Public Housing, ALN 14.872 Capital Fund Program – Noncompliance and Material Weakness Corrective Action Plan: Adopt the Local Public Agency provisions of the Kentucky Model Procurement Code contained in KRS 45A.345 through KRS 45A.460 as the Housing Authority's in conjunction with applicable federal requirements and HUD regulations as our procurement framework. Immediate Corrective Actions: o Require written procurement planning before major purchases; o Verify the correct procurement method based on the total anticipated contract value; o Require complete documentation of competition; o Document sole-source determinations when applicable; o Require Board approval for major procurements as established by revised policy; o Preserve bids, quotes, evaluations, approvals, contracts, and payment records; o Review pending procurements before award. Create a Procurement and Contract Administration Manual to include: • Procurement thresholds and approval requirements; • Board-approval requirements for major procurements; • Independent Cost Estimate procedures; • Cost and price analysis procedures; • Small-purchase procedures; • Sealed-bid procedures; • Competitive-proposal procedures; • Sole-source and noncompetitive procurement procedures; • Emergency procurement procedures; • Procurement planning checklist; • Solicitation templates; • Evaluation and scoring forms; • Conflict-of-interest certifications; • Procurement-file checklist; • Contract monitoring procedures; • Change-order procedures; • Invoice-review procedures; • Contract-closeout checklist; and Procurement training. Person Responsible: Jennifer Oberlin, Executive Director, with oversight and approval by the Board of Commissioners, where applicable. Anticipated Completion Date: October 30, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1228496 2025-002
    Material Weakness Repeat
  • 1228497 2025-003
    Material Weakness Repeat
  • 1228498 2025-004
    Material Weakness Repeat
  • 1228499 2025-006
    Material Weakness Repeat
  • 1228500 2025-007
    Material Weakness Repeat
  • 1228501 2025-002
    Material Weakness Repeat
  • 1228503 2025-002
    Material Weakness Repeat
  • 1228504 2025-005
    Material Weakness Repeat
  • 1228505 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $3.52M
14.872 PUBLIC HOUSING CAPITAL FUND $886,170
14.850 PUBLIC HOUSING OPERATING FUND $644,422
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $46,362