Finding 1240636 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-10-16
Audit: 415020
Organization: Housing Hope and Subsidiaries (WA)
Auditor: CLARK NUBER PS

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance related to procurement, specifically not following the required federal guidelines.
  • Impacted Requirements: The Agency's procurement policy does not meet the standards set by Uniform Guidance (2 CFR § 200.318), leading to noncompliance in documentation and procedures.
  • Recommended Follow-Up: Update the procurement policy to align with Uniform Guidance and ensure all procurement documentation is properly maintained.

Finding Text

Material weakness in internal controls over compliance and instances of noncompliance related to procurement. Federal Agency: U.S. Department of Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Award Number: EL-23-AR-47-048; HCS-24-AR-2107-048 Project Period: July 1, 2023 - June 30, 2026 Criteria Under 2 CFR § 200.318, a recipient must maintain and use documented procedures for procurement transactions under a federal award or subaward that are consistent with the standards identified under Uniform Guidance. In addition, recipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition/Context for Evaluation During the audit for the year ending June 30, 2025, it was noted that the Agency's procurement policy was not in compliance with Uniform Guidance. In addition, there were two selections out of four selections when the Agency was not following its own procurement policy. This is not considered a statistical sample. Cause Housing Hope's procurement policy did not include all the requirements outlined in 2 CFR 200.317 through 200.327. Effect or Potential Effect The Agency did not fully comply with the requirements regarding procurement. Questioned Costs Not applicable as finding relates to a policy not being in compliant. Repeat Finding Not applicable Recommendation We recommend that the Agency update their procurement policy to ensure procurement requirements are in line with Uniform Guidance and that proper documentation is retained for all procurements. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying management corrective action.

Corrective Action Plan

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Housing Hope adopted a Procurement Policy that aligns with the Uniform Guidance following year end. The policy was communicated to all staff with purchasing and procurement responsibilities. The policy will be reviewed at least annually to ensure continued compliance with the Uniform Guidance. In addition, management conducts periodic reviews of procurement practices to verify compliance with the Policy. Anticipated completion date: The Procurement Policy was adopted November 2025 by the Board.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1240623 2025-004
    Material Weakness Repeat
  • 1240624 2025-004
    Material Weakness Repeat
  • 1240625 2025-004
    Material Weakness Repeat
  • 1240626 2025-004
    Material Weakness Repeat
  • 1240627 2025-004
    Material Weakness Repeat
  • 1240628 2025-004
    Material Weakness Repeat
  • 1240629 2025-002
    Material Weakness Repeat
  • 1240630 2025-002
    Material Weakness Repeat
  • 1240631 2025-005
    Material Weakness Repeat
  • 1240632 2025-005
    Material Weakness Repeat
  • 1240633 2025-005
    Material Weakness Repeat
  • 1240634 2025-005
    Material Weakness Repeat
  • 1240635 2025-003
    Material Weakness Repeat
  • 1240637 2025-006
    Material Weakness Repeat
  • 1240638 2025-006
    Material Weakness Repeat
  • 1240639 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $1.05M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.04M
14.235 SUPPORTIVE HOUSING PROGRAM $400,000
10.420 RURAL SELF-HELP HOUSING TECHNICAL ASSISTANCE $322,020
14.247 SELF-HELP HOMEOWNERSHIP OPPORTUNITY PROGRAM $285,000
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $198,564
14.267 CONTINUUM OF CARE PROGRAM $90,263
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $90,000
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $81,762
10.558 CHILD AND ADULT CARE FOOD PROGRAM $28,503
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $10,999
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $7,028
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $6,696