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Historical: HUD OIG audit of NNRHA public housing funds and procurement (2007-PH-1005)

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Finding 2: The Authority Did Not Always Follow Federal Procurement Requirements When Awarding Contracts Contrary to federal procurement regulations and its own procurement policy, the Authority did not always perform required cost or price analyses to justify awarding contracts. This occurred because Authority staff did not follow established policy and was otherwise unaware of the requirements. As a result, the Authority awarded three contracts to sole bidders totaling $560,207 without having assurance that the prices were fair and reasonable. During the audit, the Authority created the documentation to properly justify awarding the three contracts. The Authority Did Not Always Perform Required Analyses The Authority did not always follow federal procurement regulations or its own procurement policy for acquiring goods and services. It was not able to provide documentation to demonstrate that three contracts awarded to sole bidders, valued at $560,207, were fair and reasonable. We selected eight contracts with values greater than $50,000 totaling $1.2 million (about 70 percent) from 150 contracts valued at $1.7 million with ending dates of September 30, 2005, or later, as of May 2006. Contrary to federal regulations and the Authority鈥檚 procurement procedures, the Authority did not prepare a cost or price analysis to justify awarding three of the eight contracts reviewed. Federal regulations 8 require that a cost or price analysis be completed when adequate price competition is lacking, such as when only one bid is received for a contract. Further, HUD Handbook 7460.8 9 states that for a sealed bid that only receives one bid, a cost analysis is required. Also, the Authority鈥檚 procurement policy 10 requires a cost or price analysis for all procurement actions and specifically states that if only one responsive bid is received from a responsible bidder, the award shall not be made unless a cost or price analysis verifies the reasonableness of the price. The following chart provides details of the three contracts. Contract type Contract amount Plumbing services $292,500 Water heaters $211,332 Heating, ventilation, and $ 56,375 air conditioning services Total $560,207 Although the Authority did not perform the required analyses before awarding the contracts, it created price analysis documentation, which properly justified 8 24 CFR [Code of Federal Regulations] 85.36(f)(1). 9 Section 4-33(B). 10 Sections F(1) and C(3). 8
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