Finding 2023-002: Schedule of Expenditures of Federal Awards (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), the
Organization is required to prepare appropriate financial statements, including the Schedule of
Expenditures of Federal Awards (SEFA).
Condition: The Organization included expenditures in its SEFA totaling $9,175 that were in
excess of allowable costs for the year ended December 31, 2023. As a result, management
provided a revised SEFA after the major program determination had already been completed.
Because the Organization had not billed the government for the excess expenditures, there were
no questioned costs.
Cause: The initial SEFA provided by management at the start of the audit was based on the profit
and loss statements, which are used to track both federal and non-federal expenditures. However,
the profit and loss statements did not specifically identify the non-federal expenditures which were
not allowed to be charged to the federal award.
Effect or Potential Effect: The SEFA could have been materially misstated. If the SEFA is not
accurately prepared, it could have an effect on the auditor's determination of major programs.
Recommendation: The Organization should implement procedures to ensure the accurate
preparation of the SEFA prior to the start of the audit.
Finding 2023-003: Procurement, Suspension, and Debarment (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions,
a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded.
This verification may be accomplished by checking the System for Award Management (SAM)
website maintained by the General Services Administration.
Condition: For all disbursements tested, the Organization could not provide documentation of their
verification, prior to payment, that the vendors were not suspended, debarred or otherwise
excluded.
Questioned Costs: NoneCause: The Organization required evidence of SAM checks be maintained in its vendor files after
conclusion of the 2022 audit, which was completed in October 2023. As a result, the Organization
did not maintain adequate support to provide evidence that appropriate suspension and debarment
searches were performed for all 2023 transactions. However, SAM checks were performed after
the fact to verify that the vendors or individuals in our sample were not suspended, debarred or
otherwise excluded. Therefore, no questioned costs have been reported related to the sample that
was tested.
Effect or Potential Effect: The Organization was not in compliance with the procurement
documentation requirements of the Uniform Guidance. As a result, the Organization could not
readily provide evidence that it had assessed whether or not its vendors were suspended,
debarred, or otherwise excluded. The potential for payments to suspended, debarred, or otherwise
excluded vendors and individuals exists.
Recommendation: The Organization should establish internal controls to ensure proper
documentation is maintained as evidence to support that the Organization performed the required
suspension and debarment searches on the SAM website.
Repeat Finding: Yes. See Finding 2022-002.
Finding 2023-002: Schedule of Expenditures of Federal Awards (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), the
Organization is required to prepare appropriate financial statements, including the Schedule of
Expenditures of Federal Awards (SEFA).
Condition: The Organization included expenditures in its SEFA totaling $9,175 that were in
excess of allowable costs for the year ended December 31, 2023. As a result, management
provided a revised SEFA after the major program determination had already been completed.
Because the Organization had not billed the government for the excess expenditures, there were
no questioned costs.
Cause: The initial SEFA provided by management at the start of the audit was based on the profit
and loss statements, which are used to track both federal and non-federal expenditures. However,
the profit and loss statements did not specifically identify the non-federal expenditures which were
not allowed to be charged to the federal award.
Effect or Potential Effect: The SEFA could have been materially misstated. If the SEFA is not
accurately prepared, it could have an effect on the auditor's determination of major programs.
Recommendation: The Organization should implement procedures to ensure the accurate
preparation of the SEFA prior to the start of the audit.
Finding 2023-003: Procurement, Suspension, and Debarment (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions,
a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded.
This verification may be accomplished by checking the System for Award Management (SAM)
website maintained by the General Services Administration.
Condition: For all disbursements tested, the Organization could not provide documentation of their
verification, prior to payment, that the vendors were not suspended, debarred or otherwise
excluded.
Questioned Costs: NoneCause: The Organization required evidence of SAM checks be maintained in its vendor files after
conclusion of the 2022 audit, which was completed in October 2023. As a result, the Organization
did not maintain adequate support to provide evidence that appropriate suspension and debarment
searches were performed for all 2023 transactions. However, SAM checks were performed after
the fact to verify that the vendors or individuals in our sample were not suspended, debarred or
otherwise excluded. Therefore, no questioned costs have been reported related to the sample that
was tested.
Effect or Potential Effect: The Organization was not in compliance with the procurement
documentation requirements of the Uniform Guidance. As a result, the Organization could not
readily provide evidence that it had assessed whether or not its vendors were suspended,
debarred, or otherwise excluded. The potential for payments to suspended, debarred, or otherwise
excluded vendors and individuals exists.
Recommendation: The Organization should establish internal controls to ensure proper
documentation is maintained as evidence to support that the Organization performed the required
suspension and debarment searches on the SAM website.
Repeat Finding: Yes. See Finding 2022-002.
Finding 2023-002: Schedule of Expenditures of Federal Awards (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), the
Organization is required to prepare appropriate financial statements, including the Schedule of
Expenditures of Federal Awards (SEFA).
Condition: The Organization included expenditures in its SEFA totaling $9,175 that were in
excess of allowable costs for the year ended December 31, 2023. As a result, management
provided a revised SEFA after the major program determination had already been completed.
Because the Organization had not billed the government for the excess expenditures, there were
no questioned costs.
Cause: The initial SEFA provided by management at the start of the audit was based on the profit
and loss statements, which are used to track both federal and non-federal expenditures. However,
the profit and loss statements did not specifically identify the non-federal expenditures which were
not allowed to be charged to the federal award.
Effect or Potential Effect: The SEFA could have been materially misstated. If the SEFA is not
accurately prepared, it could have an effect on the auditor's determination of major programs.
Recommendation: The Organization should implement procedures to ensure the accurate
preparation of the SEFA prior to the start of the audit.
Finding 2023-003: Procurement, Suspension, and Debarment (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions,
a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded.
This verification may be accomplished by checking the System for Award Management (SAM)
website maintained by the General Services Administration.
Condition: For all disbursements tested, the Organization could not provide documentation of their
verification, prior to payment, that the vendors were not suspended, debarred or otherwise
excluded.
Questioned Costs: NoneCause: The Organization required evidence of SAM checks be maintained in its vendor files after
conclusion of the 2022 audit, which was completed in October 2023. As a result, the Organization
did not maintain adequate support to provide evidence that appropriate suspension and debarment
searches were performed for all 2023 transactions. However, SAM checks were performed after
the fact to verify that the vendors or individuals in our sample were not suspended, debarred or
otherwise excluded. Therefore, no questioned costs have been reported related to the sample that
was tested.
Effect or Potential Effect: The Organization was not in compliance with the procurement
documentation requirements of the Uniform Guidance. As a result, the Organization could not
readily provide evidence that it had assessed whether or not its vendors were suspended,
debarred, or otherwise excluded. The potential for payments to suspended, debarred, or otherwise
excluded vendors and individuals exists.
Recommendation: The Organization should establish internal controls to ensure proper
documentation is maintained as evidence to support that the Organization performed the required
suspension and debarment searches on the SAM website.
Repeat Finding: Yes. See Finding 2022-002.
Finding 2023-002: Schedule of Expenditures of Federal Awards (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: In accordance with 2 CFR Section 200.508 (b), the
Organization is required to prepare appropriate financial statements, including the Schedule of
Expenditures of Federal Awards (SEFA).
Condition: The Organization included expenditures in its SEFA totaling $9,175 that were in
excess of allowable costs for the year ended December 31, 2023. As a result, management
provided a revised SEFA after the major program determination had already been completed.
Because the Organization had not billed the government for the excess expenditures, there were
no questioned costs.
Cause: The initial SEFA provided by management at the start of the audit was based on the profit
and loss statements, which are used to track both federal and non-federal expenditures. However,
the profit and loss statements did not specifically identify the non-federal expenditures which were
not allowed to be charged to the federal award.
Effect or Potential Effect: The SEFA could have been materially misstated. If the SEFA is not
accurately prepared, it could have an effect on the auditor's determination of major programs.
Recommendation: The Organization should implement procedures to ensure the accurate
preparation of the SEFA prior to the start of the audit.
Finding 2023-003: Procurement, Suspension, and Debarment (Significant Deficiency)
Federal Program: 93.129 - U.S. Department of Health and Human Services
Criteria or Specific Requirement: 2 CFR Section 200.214 requires that, for covered transactions,
a non-Federal entity must verify that entities are not suspended, debarred or otherwise excluded.
This verification may be accomplished by checking the System for Award Management (SAM)
website maintained by the General Services Administration.
Condition: For all disbursements tested, the Organization could not provide documentation of their
verification, prior to payment, that the vendors were not suspended, debarred or otherwise
excluded.
Questioned Costs: NoneCause: The Organization required evidence of SAM checks be maintained in its vendor files after
conclusion of the 2022 audit, which was completed in October 2023. As a result, the Organization
did not maintain adequate support to provide evidence that appropriate suspension and debarment
searches were performed for all 2023 transactions. However, SAM checks were performed after
the fact to verify that the vendors or individuals in our sample were not suspended, debarred or
otherwise excluded. Therefore, no questioned costs have been reported related to the sample that
was tested.
Effect or Potential Effect: The Organization was not in compliance with the procurement
documentation requirements of the Uniform Guidance. As a result, the Organization could not
readily provide evidence that it had assessed whether or not its vendors were suspended,
debarred, or otherwise excluded. The potential for payments to suspended, debarred, or otherwise
excluded vendors and individuals exists.
Recommendation: The Organization should establish internal controls to ensure proper
documentation is maintained as evidence to support that the Organization performed the required
suspension and debarment searches on the SAM website.
Repeat Finding: Yes. See Finding 2022-002.