Finding 43634 (2022-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-23
Audit: 47500
Organization: River Kourt Apartments (OR)
Auditor: Jones & Roth PC

AI Summary

  • Core Issue: River Kourt Apartments lacks complete procurement policies as required by federal regulations (2 CFR §200.318 - §200.320).
  • Impacted Requirements: Non-compliance with procurement standards increases the risk of failing to meet federal award requirements.
  • Recommended Follow-up: Revise procurement policies to include all necessary elements and ensure compliance with federal guidelines.

Finding Text

Finding 2022-003 Type of Finding: Significant deficiency in internal controls over compliance and non-compliance. Federal Award Program: HUD Supportive Housing for Persons with Disabilities (Assistance Listing #14.181) Compliance Requirement: Procurement Criteria: Pursuant to the Uniform Guidance, for procurements of goods and services made with federal awards, River Kourt Apartments is required to have policies in place that conform with the Procurement Standards as prescribed in 2 CFR ?200.318 through ?200.320. River Kourt Apartments is required to follow the methods of procurement as prescribed in 2 CFR ?200.320. Condition: River Kourt Apartments has written policies and procedures regarding the procurement of goods and services; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR ?200.318 through ?200.320. Cause of Condition: River Kourt Apartments has written policies and procedures regarding the procurement of goods and services; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR ?200.318 through ?200.320. Effect of Condition: This increases risk that River Kourt Apartments would not materially comply with the procurement requirement for the major program. Questioned Costs: None. Context: There were no procurements over the de minimis threshold made during the year period ended June 30, 2022; however, the written procedures did not include all required elements regarding procurement procedures pursuant to 2 CFR ?200.318 through ?200.320. Repeat Finding: Yes, see Finding 2021-003. Recommendation: We recommend management revise the current policies and procedures to include all required elements for procurement procedures pursuant to 2 CFR ?200.318 through ?200.320. Procurement methods shall follow the methods as prescribed in 2 CFR ?200.320. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Management?s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr Director of Finance/ShelterCare b. Catherine Fisher, Controller/ShelterCare 2. The corrective action planned: a. Internal control document and procedure that is consistent with the compliance requirement for: i. CFR ?200.318, General procurement standards Identify all requirements which the offerors must fulfill and all other factors to be used in evaluating bids or proposals ii. ?200.319, Competition. requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements iii. ?200.320 Methods of procurement to be followed. 3. The anticipated completion date: a. New processes will be implemented by 05/01/2023.

Categories

Procurement, Suspension & Debarment HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 43633 2022-002
    Significant Deficiency Repeat
  • 43635 2022-004
    Material Weakness
  • 620075 2022-002
    Significant Deficiency Repeat
  • 620076 2022-003
    Significant Deficiency Repeat
  • 620077 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.181 Supportive Housing for Persons with Disabilities $68,250