We audited the Stark Metropolitan Housing Authority’s public housing program based on significant deficiencies noted during our prior audit of the Authority.  Our audit objective was to determine whether the Authority complied with Federal and its own requirements for procuring goods and services.

The Authority did not always comply with Federal and its own procurement requirements.  Specifically, for the contracts reviewed, it did not always (1) maintain complete and consistent documentation detailing the significant history of procurements, (2) properly execute contracts for pest control services, (3) maintain sufficient documentation to support the reasonableness of contract costs, and (4) include the minimum and maximum quantity or amount in its indefinite-quantity delivery contracts.  Further, the Authority paid more than the contract value for services procured with one contractor.  These issues occurred because the Authority lacked adequate oversight, procedures, and controls over its procurements to ensure compliance with Federal and its own requirements.  As a result, HUD and the Authority lacked assurance that the Authority used Federal funds to pay for goods and services at reasonable costs.

We recommend that the Director of HUD’s Cleveland Office of Public Housing require the Authority to (1) support the reasonableness of the costs paid for its unsupported procurement and contracting activities or repay its Public Housing Operating Fund or Capital Fund program from non-Federal funds for any amount determined not to be reasonable; (2) ensure that its staff is appropriately trained on Federal procurement requirements; and (3) implement adequate procedures and controls, including but not limited to, ensuring that proper documentation is maintained, contracts are procured in accordance with Federal and the Authority’s procurement requirements, procurement staff complies with Federal procurement requirements, and payments are appropriately reconciled.  We also recommend that the Director of HUD’s Cleveland Office of Public Housing determine whether the Authority qualifies for an exemption from preaward review.