Finding 1239285 (2025-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414138
Organization: Bolton Refuge House, Inc. (WI)

AI Summary

  • Core Issue: The Organization lacks a written procurement policy for federal funds, increasing the risk of noncompliance with federal requirements.
  • Impacted Requirements: The absence of documented procedures affects compliance with the Uniform Guidance, including competition standards and contractor oversight.
  • Recommended Follow-Up: Management should develop and implement a procurement policy that meets federal guidelines, addressing key areas like purchasing thresholds and suspension checks.

Finding Text

Procurement Policy Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: 2024-2025 and 2025-2026 Award Period: October 1, 2024 – September 30, 2025 and October 1, 2025 – September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control Over Compliance and Other Matter Criteria or specific requirement: The Uniform Guidance requires non-federal entities expending federal awards to maintain and follow documented procurement policies and procedures that comply with federal requirements, including standards for competition, methods of procurement, contractor oversight, and suspension and debarment verification. Condition: The Organization has not adopted a written procurement policy governing purchases made with federal funds. As a result, procurement activities are not guided by documented procedures designed to ensure compliance with Uniform Guidance requirements. Questioned Costs: None Context: During testing of internal controls over compliance related to procurement and suspension and debarment requirements, we noted that the Organization was not able to locate a written procurement policy in place for federal awards. The Organization has had transition of staff and may have implemented in the past but current staff could not locate the policy. Cause: Management had not established formal procurement policies and procedures that incorporate federal award requirements. Effect: Without a documented procurement policy, the Organization is at increased risk of noncompliance with federal procurement requirements, including inadequate competition, inconsistent purchasing practices, failure to perform required suspension and debarment checks, and lack of documentation supporting procurement decisions. Repeat Finding: No Recommendation: We recommend management develop, approve, and implement a written procurement policy that complies with Uniform Guidance requirements. The policy should address purchasing thresholds, methods of procurement, documentation requirements, conflict-of-interest standards, contractor oversight, and procedures for verifying suspension and debarment status prior to contract award. Views of Responsible officials and planned corrective actions: Management agrees with the finding and will develop and formally adopt a procurement policy consistent with Uniform Guidance requirements. Management is working on policies and procedures and anticipates implementation prior to the next fiscal year end.

Corrective Action Plan

Procurement Policy Recommendation: We recommend management develop, approve, and implement a written procurement policy that complies with Uniform Guidance requirements. The policy should address purchasing thresholds, methods of procurement, documentation requirements, conflict-of-interest standards, contractor oversight, and procedures for verifying suspension and debarment status prior to contract award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management agrees with the finding and will develop and formally adopt a procurement policy consistent with Uniform Guidance requirements. Management is working on policies and procedures and anticipates implementation prior to the next fiscal year end. Name(s) of the contact person(s) responsible for corrective action: Harley Smalstig Planned completion date for corrective action plan: September 30, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1239284 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $447,452
16.575 CRIME VICTIM ASSISTANCE $92,064
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $75,000
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $70,000
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $64,749
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $29,988
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $19,128
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $14,112