Finding 596389 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-14
Audit: 17842
Auditor: Aprio LLP

AI Summary

  • Core Issue: Contracts were awarded without verifying if contractors were suspended or debarred, violating federal regulations and the Authority's Procurement Policy.
  • Impacted Requirements: The Authority must check the Excluded Parties List System (EPLS) or obtain certifications from contractors before awarding contracts.
  • Recommended Follow-Up: Ensure EPLS searches are documented or obtain contractor certifications to confirm compliance before future contract awards.

Finding Text

Finding 2022-001 ? Procurement/ Verification Against Contractor Suspension or Debarment (Significant Deficiency, Non-Compliance) Public Housing Program ? Assistance Listing No. 14.850a; Grant period ? year ended December 31, 2022 Criteria PHA?s are prohibited from awarding contracts to contractors who have been suspended or debarred from performing contracts funded with federal subsidies. Additionally, the Authority?s Procurement Policy states that a contract should not be awarded until the prospective contractor has been determined not to be suspended or debarred. PHA?s are permitted to comply with the applicable regulations by A) searching the Excluded Parties List System (EPLS) for the prospective contractor, or B) attaining a certified statement from the contractor in which the contractor certifies against suspension or debarment. Condition, Cause and Perspective Four Public Housing Program funded contract awards were sampled. None of the sampled contracts contained the applicable contractors? certifications against suspension and debarment or evidence that the EPLS was searched for the contractors prior to awarding the contracts. During audit fieldwork, on August 1, 2023, searches were performed and provided to the audit staff for each of the four applicable contractors. None of the contractors were suspended or debarred as of that date. Questioned Costs ? None noted Effect The Authority was unable to provide evidence supporting compliance with its Procurement Policy and federal regulations. Recommendation We recommend that the Authority A) search the EPLS for prospective contractors prior to awarding contracts and retain documentation of the searches, or B) attain certification against suspension and debarment from the prospective contractors. Management?s Response The Authority performed the applicable EPLS searches prior to awarding each of the contracts, however it did not retain documentation of the searches. The Authority will search the EPLS for prospective contractors prior to awarding contracts and retain documentation of the searches,or attain certification against suspension and debarment from the prospective contractors. The Authority?s Executive Director, Jelani Garrett, has assumed the responsibility of executing this corrective action as of September 1, 2023.

Categories

Procurement, Suspension & Debarment HUD Housing Programs

Other Findings in this Audit

  • 19947 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.850 Public and Indian Housing $10.96M
14.872 Public Housing Capital Fund $6.62M
14.870 Resident Opportunity and Supportive Services - Service Coordinators $110,658
14.892 Choice Neighborhoods Planning Grants $21,492