Pleasant Point Passamaquoddy Reservation Housing Authority

2023-001 - Special Tests and Provisions - Wage Rate Requirements Federal Program Information: Department of Housing and Urban Development: ALN - 14.867 - Indian Housing Block Grant Criteria: The following CFR(s) apply to this finding: 2 CFR 200.327 and 29 CFR 5.5. Condition: During audit procedures, it was identified that the Housing Authority’s contracts with vendors for services related to development of Tribal Housing did not include Davis- Bacon wage requirements. It was also identified that they did not obtain copies of the required certified payrolls and the accompanying Statement of Compliance. Cause: The Housing Authority does not have the necessary internal controls over compliance. Effect: The Housing Authority’s construction projects are not in compliance with Davis- Bacon wage requirements. Identification of Questioned Costs: Payments for the identified clean-up project totalled $24,185.78, all of which were performed without contracts containing the required clauses. Related certified payrolls and accompanying Statement of Compliance were not obtained for any of the payments sampled. Context: There was a repair project identified by auditors in the samples of expenses reviewed for the grant, of which had contracts with the required clauses. There were $24,185.78 payments made for this construction project, none of which had related certified payrolls and accompanying Statement of Compliance. Auditors established the potential population of two transactions. This was not a statistically valid sample. Repeat Finding: This is a repeat finding. Recommendation: It is recommended that the Housing Authority familiarize themselves with federal Wage Rate Requirements and implement internal control processes and procedures to ensure that they are following the criteria above. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the Pleasant Point Housing Authority.

2023-001 Special Tests and Provisions-Wage Rate Requirements Pleasant Point Housing Authority will be providing training to the following staff and Board of Commissioners- Procurement Policy. In addition, an extra step to the policy will be implemented with a Bid being approved by the Finance Officer and the Director before being advertised. The following items must be included in the bid package-I) Required to submit a completed Wage Hour Form 347(WH 347) and 2) A signed Statement of Compliance with the Davis Bacon Act. These items must be submitted with each request for payment for the vendor who receives the bid. In addition, the Finance Officer and Director will be responsible for making sure that the information is submitted before signing off for payment. Training on the Davis Bacon Act and compliance was held for the Director, Finance Officer, and Payable Person in July 2023 to make sure all payables to contractors have completed necessary paperwork to receive payment. A checklist form was created to attach to all contract payments with items necessaiy before payment is processed.

2022-001