Finding 2024-001
Material noncompliance and material weakness in internal control over compliance with procurement and
suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: United States Department Treasury
Program Titles: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Entity: King County Regional Homeless Authority
Award Numbers: DA-202305-01899
Award Periods: January 1, 2023 through December 31, 2023
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐
Post Federal Award Requirements, Section 200.318 through 200.327, require that a non‐Federal entity 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 requirement identified in 2
CFR Part 200.
Condition/Context
The Organization has a procurement policy, which includes procedures to include documenting the history of the
procurement, including justification of the procurement method utilized. For 2 of 2 procurements selected for
testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation
supporting the history of the procurement including justification for utilization of the noncompetitive procurement
method of procurement and performance of suspension and debarment search. The Organization determined at
the time of procurement that due to a state of public emergency the noncompetitive procurement methodology
was in compliance with the Uniform Guidance. Subsequent to procurement the Organization received approval
from the pass-through funder that a noncompetitive procurement methodology was authorized. Additionally, the
Organization documented the vendor justification and performance of suspension and debarment search
subsequent to entering into the procurement, as part of preparation for the annual audit.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was
followed by retaining documentation of the history of the procurement.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was
retained to support the history of the procurement.
Questioned Costs
$0
Repeat Finding
Repeat of finding 2023-002
Recommendation
We recommend the Organization implement internal controls to ensure that documentation is retained to support
procurements in accordance with its procurement policy.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2024-001
Material noncompliance and material weakness in internal control over compliance with procurement and
suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: United States Department Treasury
Program Titles: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Entity: King County Regional Homeless Authority
Award Numbers: DA-202305-01899
Award Periods: January 1, 2023 through December 31, 2023
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐
Post Federal Award Requirements, Section 200.318 through 200.327, require that a non‐Federal entity 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 requirement identified in 2
CFR Part 200.
Condition/Context
The Organization has a procurement policy, which includes procedures to include documenting the history of the
procurement, including justification of the procurement method utilized. For 2 of 2 procurements selected for
testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation
supporting the history of the procurement including justification for utilization of the noncompetitive procurement
method of procurement and performance of suspension and debarment search. The Organization determined at
the time of procurement that due to a state of public emergency the noncompetitive procurement methodology
was in compliance with the Uniform Guidance. Subsequent to procurement the Organization received approval
from the pass-through funder that a noncompetitive procurement methodology was authorized. Additionally, the
Organization documented the vendor justification and performance of suspension and debarment search
subsequent to entering into the procurement, as part of preparation for the annual audit.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was
followed by retaining documentation of the history of the procurement.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was
retained to support the history of the procurement.
Questioned Costs
$0
Repeat Finding
Repeat of finding 2023-002
Recommendation
We recommend the Organization implement internal controls to ensure that documentation is retained to support
procurements in accordance with its procurement policy.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2024-001
Material noncompliance and material weakness in internal control over compliance with procurement and
suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: United States Department Treasury
Program Titles: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Entity: King County Regional Homeless Authority
Award Numbers: DA-202305-01899
Award Periods: January 1, 2023 through December 31, 2023
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐
Post Federal Award Requirements, Section 200.318 through 200.327, require that a non‐Federal entity 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 requirement identified in 2
CFR Part 200.
Condition/Context
The Organization has a procurement policy, which includes procedures to include documenting the history of the
procurement, including justification of the procurement method utilized. For 2 of 2 procurements selected for
testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation
supporting the history of the procurement including justification for utilization of the noncompetitive procurement
method of procurement and performance of suspension and debarment search. The Organization determined at
the time of procurement that due to a state of public emergency the noncompetitive procurement methodology
was in compliance with the Uniform Guidance. Subsequent to procurement the Organization received approval
from the pass-through funder that a noncompetitive procurement methodology was authorized. Additionally, the
Organization documented the vendor justification and performance of suspension and debarment search
subsequent to entering into the procurement, as part of preparation for the annual audit.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was
followed by retaining documentation of the history of the procurement.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was
retained to support the history of the procurement.
Questioned Costs
$0
Repeat Finding
Repeat of finding 2023-002
Recommendation
We recommend the Organization implement internal controls to ensure that documentation is retained to support
procurements in accordance with its procurement policy.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2024-001
Material noncompliance and material weakness in internal control over compliance with procurement and
suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: United States Department Treasury
Program Titles: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Entity: King County Regional Homeless Authority
Award Numbers: DA-202305-01899
Award Periods: January 1, 2023 through December 31, 2023
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐
Post Federal Award Requirements, Section 200.318 through 200.327, require that a non‐Federal entity 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 requirement identified in 2
CFR Part 200.
Condition/Context
The Organization has a procurement policy, which includes procedures to include documenting the history of the
procurement, including justification of the procurement method utilized. For 2 of 2 procurements selected for
testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation
supporting the history of the procurement including justification for utilization of the noncompetitive procurement
method of procurement and performance of suspension and debarment search. The Organization determined at
the time of procurement that due to a state of public emergency the noncompetitive procurement methodology
was in compliance with the Uniform Guidance. Subsequent to procurement the Organization received approval
from the pass-through funder that a noncompetitive procurement methodology was authorized. Additionally, the
Organization documented the vendor justification and performance of suspension and debarment search
subsequent to entering into the procurement, as part of preparation for the annual audit.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was
followed by retaining documentation of the history of the procurement.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was
retained to support the history of the procurement.
Questioned Costs
$0
Repeat Finding
Repeat of finding 2023-002
Recommendation
We recommend the Organization implement internal controls to ensure that documentation is retained to support
procurements in accordance with its procurement policy.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2024-001
Material noncompliance and material weakness in internal control over compliance with procurement and
suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: United States Department Treasury
Program Titles: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Entity: King County Regional Homeless Authority
Award Numbers: DA-202305-01899
Award Periods: January 1, 2023 through December 31, 2023
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐
Post Federal Award Requirements, Section 200.318 through 200.327, require that a non‐Federal entity 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 requirement identified in 2
CFR Part 200.
Condition/Context
The Organization has a procurement policy, which includes procedures to include documenting the history of the
procurement, including justification of the procurement method utilized. For 2 of 2 procurements selected for
testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation
supporting the history of the procurement including justification for utilization of the noncompetitive procurement
method of procurement and performance of suspension and debarment search. The Organization determined at
the time of procurement that due to a state of public emergency the noncompetitive procurement methodology
was in compliance with the Uniform Guidance. Subsequent to procurement the Organization received approval
from the pass-through funder that a noncompetitive procurement methodology was authorized. Additionally, the
Organization documented the vendor justification and performance of suspension and debarment search
subsequent to entering into the procurement, as part of preparation for the annual audit.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was
followed by retaining documentation of the history of the procurement.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was
retained to support the history of the procurement.
Questioned Costs
$0
Repeat Finding
Repeat of finding 2023-002
Recommendation
We recommend the Organization implement internal controls to ensure that documentation is retained to support
procurements in accordance with its procurement policy.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.
Finding 2024-001
Material noncompliance and material weakness in internal control over compliance with procurement and
suspension and debarment procedures meeting the requirements of 2 CFR Part 200.
Federal Agency: United States Department Treasury
Program Titles: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Entity: King County Regional Homeless Authority
Award Numbers: DA-202305-01899
Award Periods: January 1, 2023 through December 31, 2023
Criteria
Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐
Post Federal Award Requirements, Section 200.318 through 200.327, require that a non‐Federal entity 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 requirement identified in 2
CFR Part 200.
Condition/Context
The Organization has a procurement policy, which includes procedures to include documenting the history of the
procurement, including justification of the procurement method utilized. For 2 of 2 procurements selected for
testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation
supporting the history of the procurement including justification for utilization of the noncompetitive procurement
method of procurement and performance of suspension and debarment search. The Organization determined at
the time of procurement that due to a state of public emergency the noncompetitive procurement methodology
was in compliance with the Uniform Guidance. Subsequent to procurement the Organization received approval
from the pass-through funder that a noncompetitive procurement methodology was authorized. Additionally, the
Organization documented the vendor justification and performance of suspension and debarment search
subsequent to entering into the procurement, as part of preparation for the annual audit.
Cause
The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was
followed by retaining documentation of the history of the procurement.
Effect
The Organization entered into agreements to procure goods and services for which no documentation was
retained to support the history of the procurement.
Questioned Costs
$0
Repeat Finding
Repeat of finding 2023-002
Recommendation
We recommend the Organization implement internal controls to ensure that documentation is retained to support
procurements in accordance with its procurement policy.
Views of Responsible Individual and Corrective Action Plan
Management agrees with the finding and has provided the accompanying corrective action plan.