Core Issue: Contract files are incomplete, lacking essential documentation.
Impacted Requirements: This violates HUD Procurement Policy, making it hard to verify contract progress and expenditures.
Recommended Follow-up: Review all contract files for completeness and ensure future compliance with HUD documentation standards.
Finding Text
2020-007 Incomplete Contract Files
Criteria
In accordance with HUD Procurement Policy ~ General 24 (CFR 85.36(b)(9)). The Housing Authority must maintain records sufficient to detail the significant history of each procurement action. Such documentation is particularly important in the event a protest is lodged against the Housing Authority. It will also facilitate future purchases of similar supplies or services since it will not be necessary to recreate solicitation documents. Supporting documentation shall be in writing and placed in the procurement file.
Conditions:
We noted that contract files were incomplete and missing significant documentation related to the contract.
Questioned Costs:
In excess of $3.5 million dollars.
Effect:
With incomplete contract files, it is difficult to verify the progress and expenditures related to the contracts the Fayetteville Housing Authority has entered into.
Cause:
Lack of Management oversight
Recommendation:
We recommend that the Fayetteville Housing Authority review all contract files and ensure they have complete documentation of the contract, expenditures related to that contract and progress reports. We also recommend that going forward contract files be kept in accordance to HUD procurement polies.
Corrective Action Plan
Views of Responsible Officials and Planned Corrective Actions:
Fayetteville Housing Authority management and staff will closely monitor and follow the agency procurement policy and applicable state and federal procurement requirements and thresholds. All housing authority staff with procurement/ purchasing authority will receive and review the agency procurement at least annually and immediately following approval of updates or edits. Board Commissioners will receive and review agency procurement at least annually. Responsible Parties: Audra Butler, Interim Deputy Director and FHA Board of Commissioners Finance Committee. Timeline: Procurement Policy Reviewed and Updated 12/02/2021. Staff training on procurement policy by 1/31/2022.