Finding 583606 (2023-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-01-03

AI Summary

  • Core Issue: The CDA failed to maintain timely documentation for suspension and debarment verification as required by federal regulations.
  • Impacted Requirements: Compliance with 2 CFR Part 200 regarding procurement, suspension, and debarment documentation.
  • Recommended Follow-Up: Implement internal controls to ensure proper documentation retention and oversight for compliance verification.

Finding Text

Finding 2023-003 Suspension and Debarment Federal Agency: U.S. Department of Housing and Urban Development (HUD) Federal Program Title: Public Housing Capital Fund Program Assistance Listing Number: 14.872 Federal Award Identification Number and Year: WI39P011501-20 Award Period: April 1, 2022 – March 31, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Compliance Requirements: Suspension and Debarment Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The CDA should have internal controls designed to ensure compliance with those provisions and that documentation be kept on file. This verification may be accomplished by: (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing, we noted the CDA did not have documentation on file that the verification for suspension and debarment was performed timely. Questioned costs: None Context: During our testing of the 1 contract over $25,000, it was noted that the verification documentation from SAM.gov was not kept on file at the time it was performed. It has been subsequently filed. Cause: No internal control in place to ensure documentation retained. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the CDA retain documentation of verification in its records and design a control for review and oversight of this requirement. Views of responsible officials: We agree with the finding of 2023-003 – Suspension and Debarment.

Categories

Procurement, Suspension & Debarment HUD Housing Programs

Other Findings in this Audit

  • 7163 2023-002
    Material Weakness
  • 7164 2023-003
    Significant Deficiency
  • 583605 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.872 Public Housing Capital Fund $1.15M
14.871 Section 8 Housing Choice Vouchers $263,329
14.850 Public and Indian Housing $177,947