Finding 405748 (2023-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-07-01
Audit: 311405
Organization: Nambe Pueblo Housing Entity (NM)
Auditor: Sjt Group LLC

AI Summary

  • Core Issue: Missing documentation for competitive bids and suspension checks on vendor contracts over $25,000 in the ICDBG program.
  • Impacted Requirements: Non-compliance with federal procurement policies and suspension/debarment checks as mandated by HUD.
  • Recommended Follow-up: Enhance internal controls, update procurement policies, and provide staff training on documentation and compliance processes by July 2024.

Finding Text

2023-004 – Procurement and Suspension and Debarment Federal Program Information: Funding Agency: U.S. Department of Housing and Urban Development Title: Indian Community Development Block Grant (ICDBG) Assistance Listing Number: 14.862 Award Period: October 1, 2022 – September 30, 2023 Criteria: For purchases between $10,001 and $250,000, NPHE’s procurement policy requires competitive negotiations and bids from a reasonable number of competitive sources. Additionally, a tabulation of solicitations made and quotations received shall be kept on file. Furthermore, vendors awarded contracts of $25,000 or more are required to be checked for suspension and debarment via the federal System for Award Management (SAM.gov). Condition: During our assessment of 27 ICDBG non-payroll transactions we found the following: • Six expenditures were missing documentation to support competitive negotiations and bids we obtained from a reasonable number of competitive sources. • Eight expenditures for vendor contracts over $25,000 were missing documentation to support that a suspension and debarment check was performed via SAM.gov. Questioned Costs: None. Context: Six out of 27 non-payroll transactions tested for procurement under the ICGB program. Eight out of 27 non-payroll transactions tested for suspension and debarment under the ICDBG program. Cause and Effect: The Entity did not have effective internal controls to ensure expenditures charged to the ICDBG program were properly procured and vendors paid were checked for suspension and debarment in accordance with the Entity and federal requirements. As a result, the Entity was not in compliance with these federal requirements for the ICDBG program. Auditor’s Recommendation: Improve internal controls to ensure that expenditures charged a federal award are properly procured and vendors are checked for suspension and debarment in accordance with the Entity’s policies and procedures and federal requirements. Management’s Response: NPHE will review and update the procurement policies to ensure that they clearly outline the requirements for competitive negotiations and bids. We will conduct training sessions as needed for all relevant staff to reinforce the importance of obtaining and retaining documentation for competitive negotiations and bids. This training will include best practices for procurement and record-keeping. We will also establish a standardized process for conducting suspension and debarment checks on SAM.gov and ensure that documentation of the check is included in the procurement file. Responsible Party: Interim Executive Director Anticipated Completion: July 2024

Corrective Action Plan

Corrective Action: NPHE will review and update the procurement policies to ensure that they clearly outline the requirements for competitive negotiations and bids. We will conduct training sessions as needed for all relevant staff to reinforce the importance of obtaining and retaining documentation for competitive negotiations and bids. This training will include best practices for procurement and record-keeping. We will also establish a standardized process for conducting suspension and debarment checks on SAM.gov and ensure that documentation of the check is included in the procurement file. Person Responsible: Christine Brock, Interim Executive Director Estimated Completion Date: July 31, 2024

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 405747 2023-003
    Significant Deficiency
  • 405749 2023-003
    Significant Deficiency
  • 405750 2023-004
    Significant Deficiency
  • 405751 2023-005
    Significant Deficiency
  • 405752 2023-006
    Significant Deficiency
  • 982189 2023-003
    Significant Deficiency
  • 982190 2023-004
    Significant Deficiency
  • 982191 2023-003
    Significant Deficiency
  • 982192 2023-004
    Significant Deficiency
  • 982193 2023-005
    Significant Deficiency
  • 982194 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.862 Indian Community Development Block Grant Arp Grant Receivable $736,383
14.867 Indian Housing Block Grant 2021 Grant Receivable $491,843
14.867 Indian Housing Block Grant Receivable $457,317
14.862 Indian Community Development Block Grant 2022 Grant Receivable $440,199
21.026 Covid-19 Homeowner Assistance Fund $204,735
14.867 Indian Housing Block Grant Competative 2020 Grant Receivable $24,395