Compliance with Uniform Guidance - Procurement Suspension and Debarment
Information on Federal Program: Unaccompanied Alien Children (Assistance Listing
No. 93.676) provided by the Department of Health and Human Services.
Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6
state that a non-Federal entity must review that an entity with which it plans to enter into a
covered transaction is not debarred, suspended, or otherwise excluded from participation
in federal award programs.
Condition: During our testing for procurement compliance, it was determined that the
Home did not verify that vendors charged to the major program are not debarred,
suspended, or otherwise excluded from participation in federal award programs.
Questioned Cost: None
Cause: The Home was not aware of the requirement to review an entity’s status.
Effect: The Home is not in compliance with 2 CFR Sections 200.212, 200.318(h), and
180.300 and 48 CFR Section 52.209-6. As a result, the Home could enter into covered
transactions with entities that are debarred, suspended, or otherwise excluded from
participation in federal award programs.
Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to
determine if they are debarred, suspended, or otherwise excluded from participation in
federal award programs. None were noted to be ineligible for participation.
Repeat Finding: Yes
Recommendation: We recommend the Home review and document the verification that
vendors are not debarred, suspended, or otherwise excluded from participation in federal
award programs.
Views of the Responsible Officials and Planned Corrective Actions: This item was
included in the 6/30/22 Report on Compliance for Major Federal Programs which was
finalized in February 2023. The G/L Vendor List was found to contain many inactive
vendors and was modified. Beginning in October 2023, management began sending the
vendor List to EPStaffCheck on a monthly basis. Each vendor is run through OIG (Office
of Inspector General for Excluded Individuals/Entities); OIG_Most_Wanted (Fugitives};
SAM (System for Award Management for excluded parties); SON.Office of Foreign
Assets Control (Specially Designated Nationals) and NY _Medicaid (Exclusion List).
Financial and Performance Reporting
Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No.
93.676) provided by the Department of Health and Human Services.
Criteria: Compliance under Unaccompanied Alien Children (Assistance Listing No.
93.676): Financial Reporting Requirements, submission of SF-425, Federal Financial
Report.
Condition: During our testing of compliance with the submission of the SF-425, Federal
Financial Report, we noted that seven of eight required quarterly reports were not filed by
the required due date. In addition, the annual submission for long-term foster care was
filed after the required due date.
Questioned Cost: None
Cause: The Home did not have a procedure in place to ensure that required reports were
completed and submitted by the required due dates.
Effect: Seven submissions of the quarterly, and one annual submission of Federal
Financial Report (SF-425) were not filed by the required deadlines.
Perspective Information: The Home has been operating at reduced staffing levels and has
had turnover in finance positions which has disrupted normal operations.
Repeat Finding: Yes
Recommendation: We recommend the Home implement a procedure or checklist to
ensure that the required reports are completed and submitted by the required due dates.
Views of the Responsible Officials and Planned Corrective Actions: CHP underwent a
transition in Fiscal leadership during this fiscal year. In addition, CHP was assigned a new
Grant Management Specialist that rejected FFR reports for missing information that was
not previously provided. Corrections were made following the rejections and the
resubmission dates were updated with the latter date. CHP will continue to utilize a
recurring calendar reminder.
Allowable Costs
Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No.
93.676) provided by the Department of Health and Human Services.
Criteria: 2 CFR Part 200 Section 200.403(e) states that in order for costs to be allowable
under federal awards they must be determined in accordance with generally accepted
accounting principles (GAAP). 2 CFR Part 200 Section 200.403(h) states that costs must
be incurred during the budget period.
Condition: During our testing of compliance related to allowable costs for award
90ZU041701 it was determined that costs related to the previous award (90ZU027903)
period were not claimed in the amount of $349,082.
Questioned Cost: None
Cause: The Home did not have a procedure in place to reconcile and review that claims
included all allowable expenses and that all claims were made prior to the close out of the
award period.
Effect: Award 90ZU027903 was under-claimed by $349,082 based on allowable costs.
Perspective Information: Upon commencing employment, the new Chief Financial
Officer implemented a process to review allowable costs on a weekly basis, with a year-todate
review done weekly in addition.
Repeat Finding: No
Recommendation: We recommend the Home implement a procedure to review and
reconcile that all claims for each individual award are submitted.
Views of the Responsible Officials and Planned Corrective Actions: With the transition to
a new CFO, allowable costs are now reviewed on a weekly basis, in addition to a year-todate
review being done weekly, by award.
Compliance with Uniform Guidance - Procurement Suspension and Debarment
Information on Federal Program: Unaccompanied Alien Children (Assistance Listing
No. 93.676) provided by the Department of Health and Human Services.
Criteria: 2 CFR Sections 200.212, 200.318(h), and 180.300 and 48 CFR Section 52.209-6
state that a non-Federal entity must review that an entity with which it plans to enter into a
covered transaction is not debarred, suspended, or otherwise excluded from participation
in federal award programs.
Condition: During our testing for procurement compliance, it was determined that the
Home did not verify that vendors charged to the major program are not debarred,
suspended, or otherwise excluded from participation in federal award programs.
Questioned Cost: None
Cause: The Home was not aware of the requirement to review an entity’s status.
Effect: The Home is not in compliance with 2 CFR Sections 200.212, 200.318(h), and
180.300 and 48 CFR Section 52.209-6. As a result, the Home could enter into covered
transactions with entities that are debarred, suspended, or otherwise excluded from
participation in federal award programs.
Perspective Information: Vendors in excess of the $25,000 threshold were reviewed to
determine if they are debarred, suspended, or otherwise excluded from participation in
federal award programs. None were noted to be ineligible for participation.
Repeat Finding: Yes
Recommendation: We recommend the Home review and document the verification that
vendors are not debarred, suspended, or otherwise excluded from participation in federal
award programs.
Views of the Responsible Officials and Planned Corrective Actions: This item was
included in the 6/30/22 Report on Compliance for Major Federal Programs which was
finalized in February 2023. The G/L Vendor List was found to contain many inactive
vendors and was modified. Beginning in October 2023, management began sending the
vendor List to EPStaffCheck on a monthly basis. Each vendor is run through OIG (Office
of Inspector General for Excluded Individuals/Entities); OIG_Most_Wanted (Fugitives};
SAM (System for Award Management for excluded parties); SON.Office of Foreign
Assets Control (Specially Designated Nationals) and NY _Medicaid (Exclusion List).
Financial and Performance Reporting
Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No.
93.676) provided by the Department of Health and Human Services.
Criteria: Compliance under Unaccompanied Alien Children (Assistance Listing No.
93.676): Financial Reporting Requirements, submission of SF-425, Federal Financial
Report.
Condition: During our testing of compliance with the submission of the SF-425, Federal
Financial Report, we noted that seven of eight required quarterly reports were not filed by
the required due date. In addition, the annual submission for long-term foster care was
filed after the required due date.
Questioned Cost: None
Cause: The Home did not have a procedure in place to ensure that required reports were
completed and submitted by the required due dates.
Effect: Seven submissions of the quarterly, and one annual submission of Federal
Financial Report (SF-425) were not filed by the required deadlines.
Perspective Information: The Home has been operating at reduced staffing levels and has
had turnover in finance positions which has disrupted normal operations.
Repeat Finding: Yes
Recommendation: We recommend the Home implement a procedure or checklist to
ensure that the required reports are completed and submitted by the required due dates.
Views of the Responsible Officials and Planned Corrective Actions: CHP underwent a
transition in Fiscal leadership during this fiscal year. In addition, CHP was assigned a new
Grant Management Specialist that rejected FFR reports for missing information that was
not previously provided. Corrections were made following the rejections and the
resubmission dates were updated with the latter date. CHP will continue to utilize a
recurring calendar reminder.
Allowable Costs
Information on Federal Program: Unaccompanied Alien Children (Assistance Lising No.
93.676) provided by the Department of Health and Human Services.
Criteria: 2 CFR Part 200 Section 200.403(e) states that in order for costs to be allowable
under federal awards they must be determined in accordance with generally accepted
accounting principles (GAAP). 2 CFR Part 200 Section 200.403(h) states that costs must
be incurred during the budget period.
Condition: During our testing of compliance related to allowable costs for award
90ZU041701 it was determined that costs related to the previous award (90ZU027903)
period were not claimed in the amount of $349,082.
Questioned Cost: None
Cause: The Home did not have a procedure in place to reconcile and review that claims
included all allowable expenses and that all claims were made prior to the close out of the
award period.
Effect: Award 90ZU027903 was under-claimed by $349,082 based on allowable costs.
Perspective Information: Upon commencing employment, the new Chief Financial
Officer implemented a process to review allowable costs on a weekly basis, with a year-todate
review done weekly in addition.
Repeat Finding: No
Recommendation: We recommend the Home implement a procedure to review and
reconcile that all claims for each individual award are submitted.
Views of the Responsible Officials and Planned Corrective Actions: With the transition to
a new CFO, allowable costs are now reviewed on a weekly basis, in addition to a year-todate
review being done weekly, by award.