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We performed a corrective action verification review of the audit recommendations made on the procurement practices of the Housing Authority of the City of Danbury for finding 5 of Audit Report Number 2004-BO-1004, issued December 5, 2003. This review was based on a complaint. The purpose of the review was to determine whether the selected audit recommendations were implemented and the deficiencies cited in the report were corrected.

The corrective action verification found that the Authority did not effectively implement recommendations 5A and 5E in the prior audit report. We determined that the Authority

Did not always follow HUD regulations in awarding competitive sole source contracts.
Did not always maintain adequate documentation supporting the basis for contracts awarded.
Failed to always maintain an adequate contract log detailing its past and present procurements, making it difficult to determine the number of contracts executed, their amount and type, and their current status.
Had multiple versions of its procurement policy.
May have violated ethical standards.
We recommend that the Director of HUD’s Hartford Office of Public Housing

Reopen recommendations 5A and 5E in HUD’s Audit Resolution and Corrective Action Tracking System to ensure that the Authority follows Federal procurement regulations and its own procurement policies and maintains adequate supporting documentation.
Require the Authority to create and maintain a complete, comprehensive contract log to track its past, current, and future contracts.
Consider documenting the concerns raised in this memorandum in any executed intervention strategy agreement between HUD and the Authority.
Conduct periodic inspections of the Authority’s procurement activities to ensure compliance with Federal procurement requirements.
We also recommend that the Director of HUD’s Departmental Enforcement Center

Review the actions of the Authority’s executive director and take appropriate administrative actions if warranted.