Finding 61744 (2022-004)

Material Weakness
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-09-28

AI Summary

  • Core Issue: The Authority failed to maintain adequate documentation for vendor procurement, leading to potential overspending.
  • Impacted Requirements: Noncompliance with procurement policies under 2CFR 200.67 and 2 CFR 200.88, particularly regarding the need for multiple quotes.
  • Recommended Follow-Up: Implement robust policies and procedures to ensure compliance with procurement requirements and avoid future issues.

Finding Text

2022-004 ? PROCUREMENT, SUSPENSION, AND DEBARMENT Material Weakness/Material Noncompliance U.S. Department of Housing and Urban Development CFDA #: 14.850 ? Public and Indian Housing Program CRITERIA For any amounts above the Petty Cash ceiling, but not exceeding $250,000 in accordance with revisions to 2CFR 200.67 and 2 CFR 200.88, the NBHA may use small purchase procedures. Under small purchase procedures, the NBHA shall obtain a reasonable number of quotes (preferably three); however, for purchases of less than $10,000, per NDAA Section 806 also known as Micro Purchases, only one quote is required provided the quote is reasonable. CONDITION We identified 2 instances in which sufficient documentation was not maintained to support the procurement of the vendor. CAUSE Documentation of procurement decisions was not sufficiently maintained. EFFECT The Authority has not ensured that it is receiving the most competitive prices or rates for services that have been procured, which may have resulted in unnecessary additional costs to the Authority. QUESTIONED COSTS Known Questioned Costs - $240,707, representing the aggregate payments to these two vendors. CONTEXT All purchases are required to be made in accordance with the Authority?s procurement policy. There were approximately 40 vendors paid in excess of the micro purchase threshold. We selected a sample of 4 vendors. This was not a statistically valid sample. REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend that the Authority develop and implement sufficient policies and procedures which provides for compliance with the Procurement, Suspension, and Debarment requirements of the Uniform Guidance. AUDITEE?S RESPONSE AND PLANNED CORRECTIVE ACTION See Corrective Action Plan.

Corrective Action Plan

2022-004 Procurements, Suspension and Debarment Material Weakness/Material Non-compliance For any amounts above the Petty Cash ceiling, but not exceeding $250,000 in accordance with revisions to 2CFR 200.67 and 2 CFR 200.88, the NBHA may use small purchase procedures. Under small purchase procedures, the NBHA shall obtain a reasonable number of quotes (preferably three); however, for purchases of less than $10,000, per NDAA Section 806 also known as Micro Purchases, only one quote is required provided the quote is reasonable. Auditee?s Response and Planned Corrective Action: The two vendors identified were for T & T Complete Landscaping, LLC and One Stop Electronics. T&T Complete Landscaping: The total of $187,285 paid to the vendor consisted of three separate projects: REAC preparedness: $27,300 Asphalt paving: $68,500 General Landscaping (grass/brush) $91,485 While individual quotes were procured via meetings or phone calls, the NBHA cannot produce the alternative notes to document. One stop electronics: There were 9 procurements for a total of $53,422 paid to the vendor for appliances. Due to supply chain issues, availability in addition to price varied across major retailers of appliances. The logistics clerk called each major vendor to procure the necessary quantity and best price on each occasion, but did not retain record of competitive prices. Other vendors included Home Depot, Lowes and HD supply. NBHA will maintain a file of phone quotes for future documentation. NBHA will implement sufficient policies and procedures which provides for compliance with the Procurement, Suspension, and Debarment requirements of the Uniform Guidance. Planned Implementation Date of Corrective Action: Immediate Person Responsible for Corrective Action: Director of Operations, Logistics Clerk, Director of Finance - (860)225-3534

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 61742 2022-003
    Material Weakness Repeat
  • 61743 2022-002
    Material Weakness Repeat
  • 638184 2022-003
    Material Weakness Repeat
  • 638185 2022-002
    Material Weakness Repeat
  • 638186 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.871 Section 8 Housing Choice Vouchers $8.43M
14.850 Public and Indian Housing $3.97M
14.872 Public Housing Capital Fund $545,966
14.896 Family Self-Sufficiency Program $149,487
14.870 Resident Opportunity and Supportive Services - Service Coordinators $93,296