Audit 345671

Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families Assistance Listing Number: 64.033 Federal Award Identification Number and Year: 2020-OR-272-SS – 2021, 2020-OR-272-LT 2022, 2020-OR-272-23 – 2023, 2020-OR-272-24 2024 Award Period: 2020-OR-272-SS: 09/01/2021 - 09/30/2024 2020-OR-272-LT: 08/19/2022 - 09/30/2026 2020-OR-272-23: 10/01/2022 - 09/30/2024 2020-OR-272-24: 10/01/2023 - 09/30/2024Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: Internal controls did not include maintaining the documentation of the verifiable check on www.SAM.gov for an entity’s suspension or debarment status prior to entering the covered transactions. Questioned costs: None. Context: In a statistically valid sample, CLA tested 3 of 3 covered transactions that should have been subject to suspension and debarment checks. Testing determined that no documentation was kept substantiating that S&D checks were performed, but upon review of the vendors on SAM.gov, CLA determined that none of the tested vendors were federally suspended nor debarred.Cause: Due to improper policy in place for suspension and debarment, which did not include maintaining the documentation of vendor check for suspension and debarment. Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred. Repeat Finding: No. Recommendation: CLA recommends ESO update policies to match Uniform Guidance requirements and to update procedures to require documentation is kept showing that suspension and debarment checks are done prior to entering into a covered transaction.

Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families Assistance Listing Number: 64.033 Federal Award Identification Number and Year: 2020-OR-272-SS – 2021, 2020-OR-272-LT 2022, 2020-OR-272-23 – 2023, 2020-OR-272-24 2024 Award Period: 2020-OR-272-SS: 09/01/2021 - 09/30/2024 2020-OR-272-LT: 08/19/2022 - 09/30/2026 2020-OR-272-23: 10/01/2022 - 09/30/2024 2020-OR-272-24: 10/01/2023 - 09/30/2024Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: Internal controls did not include maintaining the documentation of the verifiable check on www.SAM.gov for an entity’s suspension or debarment status prior to entering the covered transactions. Questioned costs: None. Context: In a statistically valid sample, CLA tested 3 of 3 covered transactions that should have been subject to suspension and debarment checks. Testing determined that no documentation was kept substantiating that S&D checks were performed, but upon review of the vendors on SAM.gov, CLA determined that none of the tested vendors were federally suspended nor debarred.Cause: Due to improper policy in place for suspension and debarment, which did not include maintaining the documentation of vendor check for suspension and debarment. Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred. Repeat Finding: No. Recommendation: CLA recommends ESO update policies to match Uniform Guidance requirements and to update procedures to require documentation is kept showing that suspension and debarment checks are done prior to entering into a covered transaction.