Audit 343343

Criteria: Procurement - Non-profit entities must follow the procurement standards set out at 2 CFR part 200. Condition: There was no documentation of the history of procurement including the rationale for the method of procurement and the Organization's procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause: Due to employee turnover, the policies established by the Organization were not followed. Effect: The Organization does not have adequate documentation to support rational for procurement method. Context: A sample of one disbursement totaling $32,868 was selected from a population of two transactions over the micro purchase threshold totaling $94,052 for the period July 1, 2023 - June 30, 2024. The disbursement selected for testing did not have documentation of the rationale for the method of procurement. Questioned costs: No known or likely questioned cost in excess of $25,000. Repeat Finding: No Recommendation: We recommend the Organization adhere to its policies and procedures for documenting procurement. Views of responsible officials of the auditee: The Organization concurs with the finding and will implement the following: Develop additional policies and procedures that require documentation for the method of procurement and the Organization's procedures for verifying its chosen vendor Distribute policies and procedures to all applicable finance and programmatic staff Train staff on the new policies and procedures

Criteria: Subrecipient Monitoring - Non-profit entities must follow the requirements for pass-through entities set out at 2 CFR part 200.332. Condition: Lack of documentation of subrecipient monitoring including risk assessment and whether the subrecipient is disqualified. Also, there as no indication of notification of the federal award identification number and amount of federal funds. Cause: The Organization has established policies over subrecipient monitoring and federal award identification in accordance with 2 CFR 200.332(b); however, methods for documentation of certain monitoring procedures are not formally established. Also, method for documentation of communication on federal award identification number and amount of federal funds is not contained within subaward notification on the subaward notice. Effect: The Organization does not have adequate documentation evidencing subrecipient monitoring procedures were performed or that all required information relating to federal awards was provided to subrecipients. Context: A sample of three disbursements totaling $95,377 were tested from a population of 14 transactions totaling $127,079. Questioned costs: No known or likely questioned cost in excess of $25,000. Repeat Finding: No Recommendation: We recommend the Organization establish a formal methodology for documenting subrecipient monitoring and adhere to its policies for communicating federal award identification in accordance with 2 CFR 200.332. Views of responsible officials of the auditee: The Organization concurs with the finding and will implement the following: Develop additional policies and procedures that require documentation of subrecipient monitoring including a risk assessment for each subrecipient Revise all federal subrecipient contracts to include federal award identification number and the amount of federal funds awarded to each subrecipient Distribute policies and procedures and contract templates to all applicable finance and programmatic staff Train staff on the new policies and procedures

Criteria: Procurement - Non-profit entities must follow the procurement standards set out at 2 CFR part 200. Condition: There was no documentation of the history of procurement including the rationale for the method of procurement and the Organization's procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause: Due to employee turnover, the policies established by the Organization were not followed. Effect: The Organization does not have adequate documentation to support rational for procurement method. Context: A sample of one disbursement totaling $32,868 was selected from a population of two transactions over the micro purchase threshold totaling $94,052 for the period July 1, 2023 - June 30, 2024. The disbursement selected for testing did not have documentation of the rationale for the method of procurement. Questioned costs: No known or likely questioned cost in excess of $25,000. Repeat Finding: No Recommendation: We recommend the Organization adhere to its policies and procedures for documenting procurement. Views of responsible officials of the auditee: The Organization concurs with the finding and will implement the following: Develop additional policies and procedures that require documentation for the method of procurement and the Organization's procedures for verifying its chosen vendor Distribute policies and procedures to all applicable finance and programmatic staff Train staff on the new policies and procedures

Criteria: Subrecipient Monitoring - Non-profit entities must follow the requirements for pass-through entities set out at 2 CFR part 200.332. Condition: Lack of documentation of subrecipient monitoring including risk assessment and whether the subrecipient is disqualified. Also, there as no indication of notification of the federal award identification number and amount of federal funds. Cause: The Organization has established policies over subrecipient monitoring and federal award identification in accordance with 2 CFR 200.332(b); however, methods for documentation of certain monitoring procedures are not formally established. Also, method for documentation of communication on federal award identification number and amount of federal funds is not contained within subaward notification on the subaward notice. Effect: The Organization does not have adequate documentation evidencing subrecipient monitoring procedures were performed or that all required information relating to federal awards was provided to subrecipients. Context: A sample of three disbursements totaling $95,377 were tested from a population of 14 transactions totaling $127,079. Questioned costs: No known or likely questioned cost in excess of $25,000. Repeat Finding: No Recommendation: We recommend the Organization establish a formal methodology for documenting subrecipient monitoring and adhere to its policies for communicating federal award identification in accordance with 2 CFR 200.332. Views of responsible officials of the auditee: The Organization concurs with the finding and will implement the following: Develop additional policies and procedures that require documentation of subrecipient monitoring including a risk assessment for each subrecipient Revise all federal subrecipient contracts to include federal award identification number and the amount of federal funds awarded to each subrecipient Distribute policies and procedures and contract templates to all applicable finance and programmatic staff Train staff on the new policies and procedures