Finding Text
U.S. Department of Housing and Urban Development ‐ CFDA #14.267
Continuum of Care Program
Applicable Federal Award Number and Year – AZ0089L9T022114, AZ0170L9T022106, AZ0170L9T022005, AZ0132L9T022109, AZ0132L9T022008, AZ0192L9T022003, AZ0192L9T022104, AZ0090L9T022013 ‐ 2023 / 2022
Procurement, Suspension, and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition: During our testing, we identified that the Organization was not following their procurement policy. The Organization’s procurement policy is to obtain a minimum of 3 written bids for purchases greater than $10,000. The Organization selected an approved GSA vendor as allowed by Uniform Guidance; however, the Organization didn’t obtain any written bids as required by their procurement policy.
Cause: Due to a lack of understanding of the procurement policy, the Organization did not obtain 3 written bids.
Effect: The Organization did not comply with their procurement policy.
Questioned Costs: None reported.
Context/Sampling: A non‐statistical sample of 2 expenditures were selected for testing. For 1 out of the 2 transactions selected, the Organization did not obtain 3 written bids as required by the procurement policy.
Repeat Finding from Prior Year: No
Recommendation: We recommend that the Organization implement internal controls to ensure the procurement policy is followed or update the procurement policy to follow the Organization’s current practice.
Views of Responsible Officials: Management agrees with the finding.