Finding Text
Finding 2023-001: Department of Housing and Urban Development - Continuum of Care Program -
Assistance Listing No. 14.267; Grant period: Year Ended December 31, 2023.
Criteria – In accordance with 2 CFR 200.320(a)(2)(i), participants are required to perform an appropriate form
of competition in their procurement process if purchases are within the small purchase threshold.
Condition – Management did not perform an appropriate form of competition for two purchases made within
the small purchase threshold.
Questioned costs – There are known questioned costs of $36,666 representing the reimbursements claimed
for the vendors during the audit period. No likely questioned costs are noted.
Context – Inspection of procurement documentation showed two out of two vendors subjected to sampling
required an adequate number of price or rate quotations from qualified sources to be obtained and
assessment to be performed in accordance with the small purchase threshold in the Code of Federal
Regulations; 2 CFR 200.320(a)(2)(i). Price or rate quotations were not obtained timely, nor formally
documented and a formal assessment was not performed. Of the $1,758,584 of total Continuum of Care
reimbursements claimed during the year, $60,956 of reimbursements are subject to this procurement
requirement, including the known questioned costs of $36,666.
Effect – By not obtaining price or rate quotations from qualified sources, this could result in the utilization of an
unqualified vendor, an overspending of grant funding, and questioned costs.
Cause – Management did not obtain rate quotations from an adequate number of vendors, and did not retain
sufficient documentation nor perform a formal assessment to proceed with the contracted services.
Repeat finding – This is a repeat finding as there was a procurement finding in the prior year.
Recommendation – We recommend management implement a control to ensure sufficient quotes are
obtained and documentation is retained during the procurement of all vendors being reimbursed by federal
awards and ensure compliance with the Uniform Guidance and other applicable procurement standards.
Management's response – Management has implemented a new procurement policy effective January 2024
for all vendors where the vendors will have their own procurement documents. The chosen vendors can be
the Organizaton's selected vendor from 1 to 3 years depending on type of service. All quotes and bids will be
maintained on the Organization's server.