Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Organizations are required to retain the supporting documentation for determining whether an expenditure is an allowable cost under a federal grant and to ensure the cost was charged to the appropriate grant. In addition, § 200.303(a) requires organizations to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: ICEDC lacked sufficient controls to ensure all supporting documentation was kept for general expenditures, to show that expenditures paid through autopay were adequately reviewed, and to ensure a second party reviewed the Executive Director’s (ED’s) payroll charges.
Questioned costs:
Known Questioned Costs: $2,217
Likely Questioned Costs: $25,173
Context: In a statistically valid sample, CLA tested 60 general expenditures and 11 payroll expenditures. Of those tested:
• 4 general expenditure items were found to be out of compliance with allowable activity and allowable costs provisions as the expenditures lacked adequate support and approval.
• 32 general expenditure selections were for autopay transactions. These transactions were supported by the ED’s approval of the original initiation of the costs but there was a lack of documentation to show that further reviews were done to ensure the autopay was correctly entered into the payment system and continues to be properly paid and charged to the federal program.
• 3 payroll expenditures lacked indication that the costs incurred for that employee and that time were approved. This was deemed to be an issue isolated to the timesheets of the ED.
Cause: Due to lack of staffing at the executive level to perform review and document approval of expenditures to ensure they are allowable and are accurately charged to the federal program.
Effect: Without adequate controls in place to ensure costs are reasonable and intended for the program charged, ICEDC could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that ICEDC is entitled to under the terms of the grant.
Repeat Finding: No.
Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 2 CFR Part 200 sections 200.318-327 outline the required general procurement standards, competition, and methods of procurement to be followed. These elements must be incorporated into an organization’s procurement policies and must be followed to ensure procurements are supported and covered transactions are only entered into with entities that are not federally suspended or debarred.
Condition: ICEDC’s procurement policy is not in compliance with Uniform Guidance. For the sampled procurement transactions, documentation was not retained for determining that vendors were single source, as required by Uniform Guidance. In addition, documentation was not retained showing selected entities were checked for suspension and debarment prior to entering into the covered transactions.
Questioned costs: None.
Context: As the ICEDC procurement policy did not specify a micro purchase threshold, CLA tested all procurement transactions charged to the major program that exceeded Uniform Guidance's micro purchase threshold of $10,000 (a total of 3 procurement). The transactions were found to be out of compliance with federal procurement requirements, as documentation was not retained detailing the history of the procurement; determination process of contractors as single source, including the rationale for the method of procurement; determination of contract type; basis for contractor selection; and the basis for the contract price. Documentation should be retained to evidence that an adequate number of quotes were reviewed, that price analysis was performed, and the rationale that a procurement should be considered a noncompetitive procurement. In addition, documentation was not retained showing that the procured vendors were checked for federal suspension and debarment prior to entering into the covered transactions.
Cause: Due to improper policy in place and lack of knowledge about federal procurement, suspension and debarment, and documentation requirements.
Effect: Noncompliant policies and documentation can lead to selecting vendors that are federally suspended or debarred and could result in procurement of goods and services that are unideal for the federal program.
Repeat Finding: No.
Recommendation: CLA recommends ICEDC to update the procurement policy to be compliance in with Uniform Guidance and to include more rigorous documentation as required by 2 CFR sections 200.318-200.327. ICEDC needs to ensure that policy includes the need for suspension and debarment checks to be done prior to entering into a covered transaction. CLA also recommends emphasizing the importance of the procurement standards and established policy to all authorized purchasers within ICEDC.
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331.
Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries.
Questioned costs: None.
Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award.
Cause: Lack of adequate knowledge about subrecipient monitoring requirements.
Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight.
Repeat Finding: No.
Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b).
Views of responsible officials: There is no disagreement with the audit finding.