Finding 34642 (2022-001)

Finding 2022-001: Department of Housing and Urban Development - Continuum of Care Program - Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2022. Criteria ? In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form of competition in their procurement process if purchases are within the small purchase threshold. Condition ? Management did not perform an appropriate form of competition for a purchase made within the small purchase threshold. Questioned costs ? There are known questioned costs of $36,990 representing the reimbursements claimed for the vendor during the audit period. No likely questioned costs are noted. Context ? Inspection of procurement documentation showed one out of two vendors subjected to sampling required an adequate number of price or rate quotations from qualified sources to be obtained and assessment to be performed in accordance with the small purchase threshold of 2 CFR 200.320(a)(2)(i). Price or rate quotations were obtained, but not formally documented and a formal assessment was not performed. Of the $1,625,075 of total Continuum of Care reimbursements claimed during the year, $96,702 of reimbursements are subject to this procurement requirement, including the known questioned costs of $36,990. Effect ? By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an unqualified vendor, an overspending of grant funding, and questioned costs. Cause ? Management obtained rate quotations from an adequate number of vendors, but did not retain sufficient documentation and did not perform a formal assessment to proceed with the purchase. Repeat finding ? N/A Recommendation ? We recommend management implement a control to ensure sufficient documentation is retained during the procurement of all vendors being reimbursed by federal awards and ensure compliance with the Uniform Guidance and other applicable procurement standards. Management's response ? Management will ensure to retain sufficient documentation when obtaining quotes from similar vendors and performing a documented analysis of services and corresponding costs for the fiscal year 2022?23 and every year going forward.