Brownwood Housing Authority

14.872 – Public Housing Capital Fund Material Weakness 2024-002 Procurement Criteria: The procurement regulations require the Authority to procure purchases with established thresholds. Procurement actions above established dollar amounts must be procured by acquiring bid quotes as mandated by the policy. Condition: During rehabbing of individual units, the Authority failed to properly procure the contracts. These contracts were awarded on an individual basis to a specific contractor as a unit would become vacated. The contract was not bid out as a single contract that would be used throughout the fiscal year or the grant award. Context: During our analysis of procurement transactions, we noted that quotes were not obtained during the contracting process per the procurement policy. The Authority has started preparing scope of work reports noting items to be included in the rehab project. The Authority has taken detailed procurement training. Cause: The Authority did not fully understand the procurement requirements regarding bidding out individual jobs as compared to bidding out the service or contract service as a whole. Effect: Procurement serves three main functions. First is to verify that costs are reasonable as compared to independent cost estimates and between potential contractors through the bid process. Second, it provides assurance that the Authority is approachable by potential vendors to provide services. And third, a formalized contract ensures that the services provided meet the requirements and specifications mandated by the Authority. Recommendation: We recommend that the Authority review their procurement policy and obtain training on procurement transactions, especially to understand the appropriate times in which tasks must be consolidated into a single procurement action. Bid proposals must include conditions, material types, and specifications to allow contractors to bid on an equal basis. All procurement transactions must be documented. It is recommended that a formal bid tabulation form be maintained for all contracts procured, along with the RFP if warranted, for documentation purposes. As the Authority does not probably have the resources to hire a Procurement Manager, it is recommended that the Board of Commissioners be used to review bids and the bid tabulation for purchases of a certain dollar amount. Questioned Costs: $302,715 Reply: See Reply to Finding 2024-001.

Criteria: The procurement regulations require the Authority to procure purchases with established thresholds. Procurement actions above established dollar amounts must be procured by acquiring bid quotes as mandated by the policy. Condition: During rehabbing of individual units, the Authority failed to properly procure the contracts. These contracts were awarded on an individual basis to a specific contractor as a unit would become vacated. The contract was not bid out as a single contract that would be used throughout the fiscal year or the grant award. Context: During our analysis of procurement transactions, we noted that quotes were not obtained during the contracting process per the procurement policy. Cause: The Authority did not fully understand the procurement requirements regarding bidding out individual jobs as compared to bidding out the service or contract service as a whole. Effect: Procurement serves three main functions. First is to verify that costs are reasonable as compared to independent cost estimates and between potential contractors through the bid process. Second, it provides assurance that the Authority is approachable by potential vendors to provide services. And third, a formalized contract ensures that the services provided meet the requirements and specifications mandated by the Authority. Recommendation: We recommend that the Authority review their procurement policy and obtain training on procurement transactions, especially to understand the appropriate times in which tasks must be consolidated into a single procurement action. Bid proposals must include conditions, material types, and specifications to allow contractors to bid on an equal basis. All procurement transactions must be documented. It is recommended that a formal bid tabulation form be maintained for all contracts procured, along with the RFP if warranted, for documentation purposes. As the Authority does not probably have the resources to hire a Procurement Manager, it is recommended that the Board of Commissioners be used to review bids and the bid tabulation for purchases of a certain dollar amount. Questioned Costs: $392,677

Criteria: Uniform Guidance requirements mandate that a Single Audit be performed and submitted to OMB within nine months after the end of the fiscal year. HUD also requires that an audited Financial Data Schedule (FDS) be submitted within nine months after the end of the fiscal year. Condition: The Authority had an audit firm under contract before the end of the fiscal year end. The auditor withdrew from the engagement leaving the Authority without an auditor for the fiscal year. This resulted in a failure by the Authority to submit the audit in accordance with OMB and HUD timelines. Context: We understood during the initial engagement process that the Authority would not be able to submit their audit within the required deadlines as imposed by OMB and HUD regulations. Cause: Due to the prior audit firm withdrawing from the audit engagement, the Authority was not able to contract with another audit firm in time to meet the required deadlines for the audit submission. Effect: The audit process is a valuable tool that allow regulatory agencies to monitor the financial and compliance requirements for entities. This also provides the Board of Commissioners and the public a review of the Authority’s financial condition and report on compliance. Recommendation: It is recommended that the Authority obtain a contract before the end of the fiscal year. Criteria in the selection of an audit firm should include experience in the housing industry. Reply: We have focused on getting the audit for FYE June 30, 2023 completed. The audit firm that we had contracted with had performed over one-half of the audit work when they withdrew from the engagement. It was difficult by that time to engage a new auditor that would be able to meet the filing deadlines. We were unable to hire a new auditor prior to March 31, 2024. We anticipate hiring the auditor for the fiscal year ended June 30, 2024 within the next week. The most important requirement in our contract with the auditor will be to meet the filing deadlines. From now on, we will hire the auditor prior to the end of our fiscal year. Prior to June 30, 2023, our audits and HUD filings have never been late. We will make sure that we are current in the future.

Criteria: Uniform Guidance requirements mandate that a Single Audit be performed and submitted to OMB within nine months after the end of the fiscal year. HUD also requires that an audited Financial Data Schedule (FDS) be submitted within nine months after the end of the fiscal year. Condition: The Authority had an audit firm under contract before the end of the fiscal year end. The auditor withdrew from the engagement leaving the Authority without an auditor for the fiscal year. This resulted in a failure by the Authority to submit the audit in accordance with OMB and HUD timelines. Context: We understood during the initial engagement process that the Authority would not be able to submit their audit within the required deadlines as imposed by OMB and HUD regulations. Cause: Due to the prior audit firm withdrawing from the audit engagement, the Authority was not able to contract with another audit firm in time to meet the required deadlines for the audit submission. Effect: The audit process is a valuable tool that allow regulatory agencies to monitor the financial and compliance requirements for entities. This also provides the Board of Commissioners and the public a review of the Authority’s financial condition and report on compliance. Recommendation: It is recommended that the Authority obtain a contract before the end of the fiscal year. Criteria in the selection of an audit firm should include experience in the housing industry. Reply: We have focused on getting the audit for FYE June 30, 2023 completed. The audit firm that we had contracted with had performed over one-half of the audit work when they withdrew from the engagement. It was difficult by that time to engage a new auditor that would be able to meet the filing deadlines. We were unable to hire a new auditor prior to March 31, 2024. We anticipate hiring the auditor for the fiscal year ended June 30, 2024 within the next week. The most important requirement in our contract with the auditor will be to meet the filing deadlines. From now on, we will hire the auditor prior to the end of our fiscal year. Prior to June 30, 2023, our audits and HUD filings have never been late. We will make sure that we are current in the future.