Finding Text
U.S. Department of Housing and Urban Development ‐ CFDA #14.850
Public and Indian Housing
Applicable Federal Award Number and Year – Public and Indian Housing ‐ 2022
Procurement, Suspension and Debarment
Significant Deficiency in Internal Control over Compliance
Criteria – Non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non‐federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction.
Condition – During our testing, we observed that the Authority had not retained documentation that they had performed a search for suspension and debarment. Upon our search, none of the vendors were suspended or debarred.
Questioned Costs – None Reported.
Context/Sampling – A non‐statistical sample of 7 expenditures were selected for testing. 7 out of the 7 transactions did not have proper documentation that the vendor was not suspended or disbarred.
Effect – Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Cause – Due to a lack of oversight, the Authority did not retain documentation that they had performed a search for suspension and debarment.
Repeat Finding from Prior Year – Yes.
Recommendation – The Authority should maintain documentation showing they performed a search for suspension and debarment and proper research for sole source determinations.
Views of Responsible Officials – Management agrees with the finding.