Gallia Metropolitan Housing AuthorityLocal Government

2 CFR 200.317 - 200.327 sets procurement standards for non-federal entities other than states. These non-federal entities must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. According to the Authority's Procurement Policy, for small purhcases from $3,501 to $50,000, no less than three offerors shall be solicited to submit price quotations, which may be obtained orally by telephone, or in writing, as allowed by State and local laws. Further, contracts shall not be awarded to debarred, suspended, or ineliglbe contracts. Due to deficiencies in the Authority's internal controls over compliance requireements, eight percent of the procurements tested did not follwo the Authority's policy in regards to procurement as they did not obtain and maintain price quotations for small purchases. The Authority should review the uniform guidance regulations over procurement and consider increasing their thresholds based on uniform guidiance guidelines. Further, the Authority should follow their policy and procedures for procurement.

24 CFR sections 982.158(f)(7) provides that the Public Housing Authority (PHA) must keep records to document the basis for PHA determination that rent to owner is a reasonable rent (initially and during the term of a HAP contract). 24 CFR sections 982.54(d)(15) provides the Public Housing Authority (PHA) administrative plan must cover policies on the method of determining that rent to owner is a reasonable rent (initially and during the term of a Housing Assistance Payment contract). The Authority?s Housing Choice Voucher Administrative Plan Section 13(5)(c) provides the Authority will retain the following in the tenant file: 1. Request for Lease Approval 2. Lease 3. Inspection report(s) 4. Certification of Rent Reasonableness 5. Executed contract. The Authority could not provide the reasonable rent certifications for 44 percent of the current tenant files tested for the Housing Choice Voucher program. The tenants lacking this certification in their file had been in the program for several years or were new to the program in 2022. The Authority also could not provide the reasonable rent certification for 67 percent of the new participant tenant files tested for the Housing Choice Voucher Program. The tenants lacking this certification in their file had been admitted into the program during 2022. The failure to document rent reasonableness could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Housing and Urban Development. The Executive Director and Housing Choice Voucher employees should ensure all tenant files maintain the appropriate documentation and meet the requirements for rent reasonableness.

24 CFR section 982.158(d) provides that the Public Housing Authority (PHA) must prepare a unit inspection report. Further, 24 CFR section 982.405(a) provides that the PHA must inspect the unit leased to a family prior to the initial term of the lease, at least biennially during assisted occupancy, and at other times as needed, to determine if the unit meets the HQS. The Authority did not perform housing quality inspections in 2022 for 87.5 percent of the current tenant files tested for the Housing Choice Voucher program. The failure to perform housing quality inspections could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Urban development. The Executive Director and Housing Choice Voucher Manager should ensure all tenant files maintain the appropriate documentation and meet the requirements for inspections.

24 CFR section 982.158(d) provides that the Public Housing Authority (PHA) must prepare a unit inspection report. Further, 24 CFR section 982.405(a) provides that the PHA must inspect the unit leased to a family prior to the initial term of the lease, at least biennially during assisted occupancy, and at other times as needed, to determine if the unit meets the HQS. Notice PIH 2021-14 (HA) provides a waiver for the biennial inspections through December 31, 2021. Under this waiver authority, PHAs may delay biennial inspections for both tenant-based and PBV units and instead, the PHA may rely on the owner?s certification that the owner has no reasonable basis to have knowledge that life-threatening conditions exist in the unit or units in question. At minimum, the PHA must require this owner certification. The Authority did not perform any inspections in 2021 for the Housing Choice Voucher program due to the COVID-19 pandemic as allowed by approved waiver. However, the Authority did not obtain any owner certifications as required by the waiver as required alternative procedures. The failure to obtain required inspections or the alternate owner certifications could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Housing and Urban Development. The Executive Director and Housing Choice Voucher Manager should ensure all tenant files maintain the appropriate documentation and meet the requirements for inspections.