Finding Text
Finding 2022-003 ? Non-compliance with Internal Procurement Policy (Material Weakness, Material Non-Compliance) Capital Fund Program ? Assistance Listing No. 14.872, Grant Period: Fiscal Year-End June 30, 2022 Criteria Public Housing Authorities (PHA?s) should procure federally-funded contracts in accordance with a formal, documented internal Procurement Policy based on federal procurement guidelines, including HUD Handbook 7460.8, Rev. 2, Procurement Handbook for Public Housing Agencies. 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 Two Capital Fund Program funded contract awards were sampled. One applicable contact, awarded in the amount of $120,725, did not contain the contractor?s certification against suspension and debarment or evidence that the EPLS was searched for the contractor. Questioned Costs - $76,705 was expended under the contract during fiscal year 2022. Effect Non-compliance with the Authority?s Procurement Policy and federal regulations. Recommendation We recommend that the Authority attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. Management?s Response The Authority will attain certification against suspension and debarment or search the EPLS for prospective contractors prior to awarding contracts. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.