Low Rent Program-CDFA#14.850
Finding 2023-001-Non-Compliance With Procurement Policy-Procurement
Criteria and Condition
All amounts above the Small Purchase Threshold (SMT) should follow the Procurement Policy. Depending on the amount, telephone, email, or written bids may be acceptable. In other instances, depending on the estimated amount of the expenditure, more strict methods are required by both the Authority’s Procurement Policy and also federal regulations regarding procurement. Even when individual expenditure amounts paid are below the SMT, if it reasonable to assume that similar expenditures through the year will in total exceed the SMT, obtaining other quotes is still required.
Context
It appears that the Authority did not solicit bids or quotes from other contractors for the following expenditures:
(a)-2020 CFP-closed to fixed assets during the year, 39 payments, largest $5,400, 5 different contractors $145,804
(b)-2021 CFP-closed to fixed assets during the year, 64 payments, largest $35,447,
most less than $6,000, 6 different contractors $309,734
(c)-Heating-cooling expenditures, 24 payments, largest $2,588, 2 different contractors $23,204
(d)-Landscape and grounds contracts, 28 payments, largest $1,700, 2 different contractors $50,020
(e)-Plumbing, 33 payments, largest $2,099, 2 different contractors $20,726 Effect
The possibility of paying more than a reasonable charge was not reduced to a lower level by soliciting quotes for the same service. Management asserts that there are few local contractors that will perform a satisfactory service and do it in a timely manner. Often the service required may not be a technical emergency. Nevertheless, management asserts, the service such as a toilet plumbing issue or the lack of air conditioning, in hot weather is a near emergency. Management asserts that through trial and error, they have determined who can do reliable and timely work. Management asserts that when they are aware of a new entity offering services, they are willing to give the new company a try.
Cause
It is management’s oversight that quotes were not obtained.
Questioned Costs
None
Recommendation
In our audit period, the Authority did not do large, turnkey general contractor jobs.
We realize that it is not practical to bid out services rendered for similar services in all instances. For example, as noted above, 64 payments were made for 2021 CFP in the audit period. Many of the 64 were payments for more than one service.
However, management should periodically solicit and obtain quotes for representative types of work. Perhaps the easiest is for uniform types of work where problems are not anticipated. The RFP should list the factors considered for the award, with emphasis that price is not the sole determining factor. Then, for this type of uniform work, for subsequent jobs, the Authority could consider not soliciting bids until a reasonable number of jobs were done, or a specified period of lapsed time-six months for example.
For some jobs, it is not known what will be encountered until the job is in progress, plumbing being just one example. In these instances, quotes and bids should be obtained on hourly rates. Again, for a specified number of jobs thereafter of a reasonable period of time, quotes would not need to be obtained for subsequent, similar jobs.
We reviewed the proof of insurance on the contractors on a heavy basis. We did not note any exceptions.
When management is unable to obtain at least three quotes or meet the stricter requirements required by regulations and its Procurement Policy, for larger expenditures, they should document their attempts to obtain quotes from larger, nearby locales. Likely those out- of- town entities will charge more to cover transportation costs and their quotes will not be competitive. They may not meet the need to timely perform requirement. In those instances, the Authority should obtain quotes of what those entities charge in their locale (Wichita Falls, Oklahoma City, etc,) as documentation that what the Authority being charged is reasonable.
View of Responsible Official
I am Rita Love, Executive Director and Designated Person to answer these audit findings. We will comply with the auditor’s recommendation.
(f)-Exterminating, 21 payments, largest $1,400, 2 different contractors $17,740
(g)-Janitorial, 30 payments, largest $13,410 (3 locations-9 months’ service at each location), most in the $2,000 range $65,090
Total $632,318