THE HOUSING AUTHORITY OF THE CITY OF TRENTON

Finding 2022-001 ? Procurement/ Verification Against Contractor Suspension or Debarment (Significant Deficiency, Non-Compliance) Public Housing Program ? Assistance Listing No. 14.850a; Grant period ? year ended December 31, 2022 Criteria PHA?s are prohibited from awarding contracts to contractors who have been suspended or debarred from performing contracts funded with federal subsidies. Additionally, the Authority?s Procurement Policy states that a contract should not be awarded until the prospective contractor has been determined not to be suspended or debarred. PHA?s are permitted to comply with the applicable regulations by A) searching the Excluded Parties List System (EPLS) for the prospective contractor, or B) attaining a certified statement from the contractor in which the contractor certifies against suspension or debarment. Condition, Cause and Perspective Four Public Housing Program funded contract awards were sampled. None of the sampled contracts contained the applicable contractors? certifications against suspension and debarment or evidence that the EPLS was searched for the contractors prior to awarding the contracts. During audit fieldwork, on August 1, 2023, searches were performed and provided to the audit staff for each of the four applicable contractors. None of the contractors were suspended or debarred as of that date. Questioned Costs ? None noted Effect The Authority was unable to provide evidence supporting compliance with its Procurement Policy and federal regulations. Recommendation We recommend that the Authority A) search the EPLS for prospective contractors prior to awarding contracts and retain documentation of the searches, or B) attain certification against suspension and debarment from the prospective contractors. Management?s Response The Authority performed the applicable EPLS searches prior to awarding each of the contracts, however it did not retain documentation of the searches. The Authority will search the EPLS for prospective contractors prior to awarding contracts and retain documentation of the searches,or attain certification against suspension and debarment from the prospective contractors. The Authority?s Executive Director, Jelani Garrett, has assumed the responsibility of executing this corrective action as of September 1, 2023.

Finding 2021-001 ? Tenant Eligibility, Reexaminations and Physical Inspections of Units (Material Weakness, Material Noncompliance) Public Housing Program ? Assistance Listing No. 14.850a; Grant period ? year ended December 31, 2021 Criteria The Public Housing Occupancy Guidebook and other HUD PIH Notices and Handbooks provide requirements and guidance for which the Public Housing Program is to be administered and operated under with respect to tenant eligibility and reexaminations. Specifically, the Authority must A) conduct annual reexaminations for all persons and families assisted under the Program, and B) conduct physical inspections of units annually. Condition and Perspective During audit fieldwork, forty Public Housing Program tenant files were requested for review for compliance with Program eligibility and reexamination requirements. The following omissions were noted from the files: 1) 2 files were missing Lead-Based Paint Disclosure Forms 2) 10 files were missing Physical Inspection Reports 3) 3 files were missing a third-party verification of income 4) 2 files were missing a birth certificate or ID card 5) 1 file was missing a social security card 6) 1 file contained an incorrect income calculation on the HUD Form 50058 Cause Failure to execute controls over annual tenant reexaminations and tenant file maintenance requirements. Effect Non-compliance with the HUD?s reexamination and physical inspection requirements. Questioned Costs ? None noted. Recommendation We recommend that the Authority implement and execute strengthened controls over the annual tenant reexaminations, tenant file maintenance and unit inspection processes. Reply The Authority will implement and execute strengthened controls over the annual tenant reexaminations, tenant file maintenance and unit inspection processes. Jelani Garrett, Executive Director, has assumed the responsibility of implementing and executing strengthened controls over the annual tenant reexaminations, tenant file maintenance and unit inspection processes and expects the deficiencies which led to this Finding to be resolved by December 31, 2022.

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