Finding 498064 (2023-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-24

AI Summary

  • Core Issue: The Authority did not obtain bids or check for suspension and debarment for a significant procurement transaction, violating federal competition standards.
  • Impacted Requirements: This oversight breaches 2 CFR Section 200.319, which mandates open competition for federal procurement transactions.
  • Recommended Follow-Up: Ensure compliance by training staff on the new procurement policy and maintaining proper documentation for all purchases.

Finding Text

Finding 2023 – 002: Procurement Policy and Documentation on Procurement CFDA 14.867 – Indian Housing Block Grant Material Weakness Condition: During our review of procurement, suspension and debarment, we reviewed one transaction that met the capitalization threshold. It was determined that there were no bids obtained and there was not a search for suspension and debarment performed. Criteria: In accordance with 2 CFR Section 200.319, all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner provided full and open competition consistent with the standards of this section and Section 200.320. Questioned Costs: None. Effect: Lack of adherence to policies and procedures consistent with Uniform Guidance procurement standards for the whole fiscal year could result in the Authority being non-compliant on purchases made with federal funds. Cause: The Authority did adopt a new procurement policy addressing 2 CFR Section 200.319 in June of 2023. Due to the timing of the adoption of the updated policy, it was not implemented during the whole fiscal year under audit. Recommendation: We recommend the Authority adhere to their policy and that all documentation related to procurement decisions be kept for all purchases according to the dollar threshold requirements and that all staff be trained in these procedures. Response: See the corrective action plan that accompanies the schedule of findings and questioned costs.

Corrective Action Plan

FINDING 2023-02 PROCUREMENT POLICY AND DOCUMENTATION (Background info) As mentioned in the audit, the SSTHA Board of Commissioners adopted a new Procurement Policy, and they also adopted an addendum to that policy that was mandated in a previous audit disclosure. Unfortunately, within 2 years the SSTHA had significant employee turnover within its maintenance and development operation. Four employees retired, re-located, and/or deceased. Consequently, the matter of training in procurement is ongoing but vested in that procurement compliance is key in the qualification review process for new grants. FINDING 2023-02 PROCUREMENT POLICY AND DOCUMENTATION (Corrective Action) Procurement training has been an ongoing process, particularly by way of bidding. Additional training shall be initiated through budget cost accounting, purchasing through proposals, document retention, and debarment shall be undertaken with the accounting aspect training referenced in Finding #1 above.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
14.867 Indian Housing Block Grants $1.01M
14.862 Indian Community Development Block Grant Program $351,380