Finding 404105 (2023-002)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2024-06-28
Audit: 310889
Organization: Rochester Housing Authority (NY)

AI Summary

  • Core Issue: The Authority failed to provide documentation for one procurement contract, raising concerns about compliance with federal regulations.
  • Impacted Requirements: Lack of documentation prevents verification of contractor eligibility and adherence to procurement rules, potentially leading to higher costs.
  • Recommended Follow-Up: Implement a comprehensive contract documentation process, evaluate open-end contracts annually, and enhance procurement training for staff.

Finding Text

Criteria - Under the Procurement, Suspension, and Debarment compliance requirement for the Public and Indian Housing Program (Assistance Listing Number 14.850), small purchases in excess of $1,000, but not exceeding $25,000 no less than three offerors shall be solicited to submit price quotations. These quotes may be obtained orally, by telephone, or in writing, as allowed by State or local laws. Award shall be made to the offeror providing the lowest acceptable quotation, unless justified in writing based on price and other specified factors, such as for architect-engineer contracts. If non-price factors are used, they shall be disclosed to all those solicited. The names, addresses, and/or telephone numbers of the offerors and persons contacted, and the date and amount of each quotation shall be recorded and maintained as a public record (unless otherwise provided in State or local law). For purchases above the Authority’s small purchase threshold, the level of detail will vary but should be commensurate with the size (i.e. dollar value), complexity, and commercial nature of the requirement. Condition - During our testwork over compliance with the Procurement, Suspension, and Debarment requirements of the Public and Indian Housing Program (14.850), we selected three procurement contracts for review and the Authority was unable to provide one of the selected contracts. As a result, we were unable to ensure that the contract adheres to federal regulations and the contractors were not suspended, debarred, or otherwise excluded from participating in federal programs. Cause - The Authority does not have a process in place for documenting contracts procured throughout the year to ensure all compliance requirements are properly met. Effect - The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. Questioned Costs - $9,368 Recommendation - We recommend the Authority make the following improvements to internal controls: • Evaluate the need for open-end contracts and procure these services in accordance with the procurement policy at least annually. • Ensure there is a comprehensive process in place to meet the requirements necessary for sole-source and emergency procurements. • Provide sufficient procurement training to all employees responsible for procurement. Management’s Response - (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action taken. (b) Action taken - Procurement policies over record retention will be implemented. (c) Planned implementation date of corrective action - Completed by September 30, 2024.

Corrective Action Plan

Name of Auditee: Rochester Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: September 30, 2023 CAP Prepared by: Shawn Burr, Executive Director Phone: (585) 697-6184 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2023-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action taken. (b) Action taken - Procurement policies over record retention will be implemented. (c) Planned implementation date of corrective action - Completed by September 30, 2024.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 404104 2023-003
    Significant Deficiency Repeat
  • 980546 2023-003
    Significant Deficiency Repeat
  • 980547 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.850 Public and Indian Housing $9.82M
14.872 Public Housing Capital Fund $5.74M
14.879 Mainstream Vouchers $2.34M
14.238 Shelter Plus Care $1.76M
14.871 Section 8 Housing Choice Vouchers $978,614
14.249 Section 8 Moderate Rehabilitation Single Room Occupancy $237,649
14.896 Family Self-Sufficiency Program $232,680
14.870 Resident Opportunity and Supportive Services - Service Coordinators $213,472