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.