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