Finding 1236499 (2025-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-24
Audit: 412020
Organization: Chicago Housing Authority (IL)
Auditor: ERNST YOUNG LLP

AI Summary

  • Core Issue: The Authority failed to obtain necessary Board approval for a procurement transaction and did not document suspension and debarment checks for certain contracts.
  • Impacted Requirements: This violates Uniform Guidance procurement standards and internal control procedures, risking non-compliance with federal regulations.
  • Recommended Follow-Up: The Authority should strictly adhere to its internal controls for procurement approvals and ensure proper documentation of suspension and debarment checks moving forward.

Finding Text

Finding 2025-006 I. Procurement, Suspension and Debarment Identification of the Federal Program: Federal Agency: U.S. Department of Housing and Urban Development (HUD) Federal Assistance Listing Number: 14.881 Federal Program Name: Moving to Work (MTW) Demonstration Program Public and Indian Housing (Public Housing) Program Year: January 1, 2025 through December 31, 2025 Program No.: IL002-01-00025D Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR section 200.303 states, “The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.318, general procurement standards states “(a) Documented procurement procedures. The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services.” The Uniform Guidance 2 CFR section 200.319 states that “all procurement transactions under the Federal award must be conducted in a manner that provides for full and open competition and is consistent with the standards of this section and §200.320.” The Authority’s procurement policy for an intergovernmental purchasing agreement requires an agency contract and amendments. The Authority’s internal control procedures require procurements of more than $500,000 to have Board of Commissioners’ approval. Recipients and subrecipients are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220. When a recipient or subrecipient enters into a covered transaction with an entity at a lower tier, the recipient or subrecipient must verify that the entity, as defined in 2 CFR 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR 180.300). Condition: For one of nine (11.1%) procurement transactions and one of 40 (2.5%) procurement transactions tested for internal controls over and compliance with federal procurement compliance requirements, respectively, we identified one procurement exception. Specifically, the procurement lacked Board of Commissioners approval, and no executed agreement or amendment existed for fiscal year 2025. Therefore, the Authority was unable to demonstrate compliance with Uniform Guidance procurement standards. For three of 40 (7.5%) procurement transactions tested for internal controls over and compliance with the suspension and debarment compliance requirement, the suspension and debarment check was not performed or retained on file before entering the covered transaction. Therefore, the Authority was unable to demonstrate compliance with Uniform Guidance suspension and debarment standards. Cause: The Authority’s internal controls over the review and approval of procurement transactions and the review and retention of suspension and debarment checks were not operating effectively. Effect or Potential Effect: Procurements may not be made in accordance with Uniform Guidance procurement standards. Contractors/vendors may be suspended or debarred. Questioned Costs: A total of $6,412,600 related to Assistance Listing No. 14.881, representing one procurement with a procurement exception (invoices totaling $6,412,600). Context: The one procurement and three suspension and debarment transactions totaled $8,443,452 out of 40 procurement transactions sampled for compliance totaling $38,544,823. Public Housing expenditures reported in the schedule of expenditures of federal awards were $253,935,873 for the year ended December 31, 2025, representing 21.32% of total federal expenditures under Assistance Listing No. 14.881 of $1,190,937,657. Identification as a Repeat Finding, if Applicable: The finding is a partial repeat of finding 2024-006 from the prior year. Recommendation: The Authority should follow its established internal controls over the review and approval of procurement transactions and the review and retention of suspension and debarment checks. Views of Responsible Officials: CHA Management agrees. This finding pertains to an intergovernmental contractual agreement with the Chicago Police Department, which was under renegotiation and not yet approved by the Board. Although the suspension and debarment check had been performed, it was not documented in accordance with CHA procedures. Going forward, the CHA will ensure compliance with its existing procurement process and procedures.

Corrective Action Plan

Finding 2025-006 I. Procurement, Suspension and Debarment Procurement Approval and Executed Agreement Compliance Management agrees with the finding and has outlined the following corrective actions: • Obtain Board approval for a new intergovernmental agreement for Chicago Police Department at the September 2026 board meeting. • Complete a full review of 2025 and 2026 procurement files by the end of Q1-2027 to ensure all required Board approvals and executed agreements are retained. • Strengthen internal workflows to prevent procurement actions from proceeding without verified approvals and executed agreements through inclusion of a new checklist which will be reflected in an updated standard operating procedures (SOP). • Provide refresher training to procurement staff on 2 CFR 200 documentation retention requirements by December 2026. Suspension and Debarment Compliance Management concurs with the findings and will implement: • Semiannual targeted training to reinforce staff responsibilities for verifying vendor eligibility and documenting compliance to begin December 2026. • Enhanced managerial monitoring through a standardized checklist to ensure required suspension/debarment checks are completed and retained before issuing purchase orders. Implemented January 2027. Responsible for Corrective Action: Tamika Carson, Director of Procurement; Sheila Johnson, Deputy Chief Procurement Anticipated Completion Date: Q1-2027

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

Other Findings in this Audit

  • 1236484 2025-001
    Material Weakness Repeat
  • 1236485 2025-005
    Material Weakness Repeat
  • 1236486 2025-001
    Material Weakness Repeat
  • 1236487 2025-003
    Material Weakness Repeat
  • 1236488 2025-004
    Material Weakness Repeat
  • 1236489 2025-001
    Material Weakness Repeat
  • 1236490 2025-003
    Material Weakness Repeat
  • 1236491 2025-004
    Material Weakness Repeat
  • 1236492 2025-001
    Material Weakness Repeat
  • 1236493 2025-003
    Material Weakness Repeat
  • 1236494 2025-004
    Material Weakness Repeat
  • 1236495 2025-001
    Material Weakness Repeat
  • 1236496 2025-002
    Material Weakness Repeat
  • 1236497 2025-003
    Material Weakness Repeat
  • 1236498 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 MOVING TO WORK DEMONSTRATION PROGRAM $1.19B
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $16.96M
14.879 MAINSTREAM VOUCHERS $4.87M
14.856 LOWER INCOME HOUSING ASSISTANCE PROGRAM SECTION 8 MODERATE REHABILITATION $4.24M
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM $1.59M
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $1.35M
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $850,000
14.870 RESIDENT OPPORTUNITY AND SUPPORTIVE SERVICES - SERVICE COORDINATORS $307,853
14.895 JOBS-PLUS PILOT INITIATIVE $303,511