Finding 2024-001 – Procurement, suspension and debarment
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000.
A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person.
Condition: During fiscal year 2024, the Organization contracted with one vendor for services who was paid more than $25,000. There was no evidence documenting that this vendor had been checked for suspension and debarment prior to payment.
Cause: The Organization was aware of the requirement, the verification appears to have been an oversight.
Effect: Without verifying whether a vendor has been suspended or debarred prior to payment, the Organization faces a heightened risk that they are expending federal dollars to excluded parties.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization perform and document each verification on vendors over $25,000 prior to funds being disbursed. An alternative would be for the standard contract to address suspension and debarment and obtain the certification from the vendors at the time the contract is executed.
Response: As of the release of this audit, NFFCMH has 1) collected a Certification from the specific vendor verifying that the Vendor is not excluded or disqualified, 2) going forward the Organization will include a clause to that specific vendor to maintain that status, and 3) NFFCMH will perform a SAM search on the first day of each contract start and renewal date going forward for all applicable vendors.
Finding 2024-002 – Allowable costs – payroll
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated.
The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time.
Condition: During fiscal year 2024, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs.
Cause: Management was made aware that using budget estimates was not allowed without further reconciliation against actual time or effort activities during the fiscal year 2022 audit which was completed in April 2024. Management has not yet implemented changes to its internal processes to address the identified issue.
Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis.
Response: The Organization is acting upon different guidance it has received. As of the date this audit is released, the contract this finding addresses is currently scheduled to end on 08/30/2025. NFFCMH will continue our current practice through the end of the current contract, and will review any potential change to same with any renewal of this contract.
Finding 2024-001 – Procurement, suspension and debarment
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000.
A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person.
Condition: During fiscal year 2024, the Organization contracted with one vendor for services who was paid more than $25,000. There was no evidence documenting that this vendor had been checked for suspension and debarment prior to payment.
Cause: The Organization was aware of the requirement, the verification appears to have been an oversight.
Effect: Without verifying whether a vendor has been suspended or debarred prior to payment, the Organization faces a heightened risk that they are expending federal dollars to excluded parties.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization perform and document each verification on vendors over $25,000 prior to funds being disbursed. An alternative would be for the standard contract to address suspension and debarment and obtain the certification from the vendors at the time the contract is executed.
Response: As of the release of this audit, NFFCMH has 1) collected a Certification from the specific vendor verifying that the Vendor is not excluded or disqualified, 2) going forward the Organization will include a clause to that specific vendor to maintain that status, and 3) NFFCMH will perform a SAM search on the first day of each contract start and renewal date going forward for all applicable vendors.
Finding 2024-002 – Allowable costs – payroll
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated.
The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time.
Condition: During fiscal year 2024, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs.
Cause: Management was made aware that using budget estimates was not allowed without further reconciliation against actual time or effort activities during the fiscal year 2022 audit which was completed in April 2024. Management has not yet implemented changes to its internal processes to address the identified issue.
Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis.
Response: The Organization is acting upon different guidance it has received. As of the date this audit is released, the contract this finding addresses is currently scheduled to end on 08/30/2025. NFFCMH will continue our current practice through the end of the current contract, and will review any potential change to same with any renewal of this contract.
Finding 2024-001 – Procurement, suspension and debarment
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000.
A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person.
Condition: During fiscal year 2024, the Organization contracted with one vendor for services who was paid more than $25,000. There was no evidence documenting that this vendor had been checked for suspension and debarment prior to payment.
Cause: The Organization was aware of the requirement, the verification appears to have been an oversight.
Effect: Without verifying whether a vendor has been suspended or debarred prior to payment, the Organization faces a heightened risk that they are expending federal dollars to excluded parties.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization perform and document each verification on vendors over $25,000 prior to funds being disbursed. An alternative would be for the standard contract to address suspension and debarment and obtain the certification from the vendors at the time the contract is executed.
Response: As of the release of this audit, NFFCMH has 1) collected a Certification from the specific vendor verifying that the Vendor is not excluded or disqualified, 2) going forward the Organization will include a clause to that specific vendor to maintain that status, and 3) NFFCMH will perform a SAM search on the first day of each contract start and renewal date going forward for all applicable vendors.
Finding 2024-002 – Allowable costs – payroll
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated.
The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time.
Condition: During fiscal year 2024, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs.
Cause: Management was made aware that using budget estimates was not allowed without further reconciliation against actual time or effort activities during the fiscal year 2022 audit which was completed in April 2024. Management has not yet implemented changes to its internal processes to address the identified issue.
Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis.
Response: The Organization is acting upon different guidance it has received. As of the date this audit is released, the contract this finding addresses is currently scheduled to end on 08/30/2025. NFFCMH will continue our current practice through the end of the current contract, and will review any potential change to same with any renewal of this contract.
Finding 2024-001 – Procurement, suspension and debarment
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000.
A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person.
Condition: During fiscal year 2024, the Organization contracted with one vendor for services who was paid more than $25,000. There was no evidence documenting that this vendor had been checked for suspension and debarment prior to payment.
Cause: The Organization was aware of the requirement, the verification appears to have been an oversight.
Effect: Without verifying whether a vendor has been suspended or debarred prior to payment, the Organization faces a heightened risk that they are expending federal dollars to excluded parties.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization perform and document each verification on vendors over $25,000 prior to funds being disbursed. An alternative would be for the standard contract to address suspension and debarment and obtain the certification from the vendors at the time the contract is executed.
Response: As of the release of this audit, NFFCMH has 1) collected a Certification from the specific vendor verifying that the Vendor is not excluded or disqualified, 2) going forward the Organization will include a clause to that specific vendor to maintain that status, and 3) NFFCMH will perform a SAM search on the first day of each contract start and renewal date going forward for all applicable vendors.
Finding 2024-002 – Allowable costs – payroll
Assistance Listing #: 93.243
Criteria: In accordance with the Uniform Guidance’s compensation requirements (2 CFR 200.430), payroll systems must be based on records that accurately reflect the work performed and supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated.
The Uniform Guidance allows for use of budget estimates on an interim basis. When using budget estimates on an interim basis, grantees must reconcile estimates against actual time or effort on a regular basis to ensure that estimates conform to actual staff activity. Grantees must make adjustments in the payroll distribution to align with actual time.
Condition: During fiscal year 2024, the Organization charged payroll costs to the federal award programs using a set percentage based on budget and not based on employee’s actual time or effort amongst various programs.
Cause: Management was made aware that using budget estimates was not allowed without further reconciliation against actual time or effort activities during the fiscal year 2022 audit which was completed in April 2024. Management has not yet implemented changes to its internal processes to address the identified issue.
Effect: The salary costs charged to the federal programs may have been under or over reported based on the actual level of effort.
Questioned Costs: N/A
Repeat Finding: Yes
Recommendation: We recommend the Organization make changes overall its timekeeping processes to ensure that payroll costs accurately reflect the work performed and if budget estimates are utilized, that they are reconciled and trued up on a consistent basis.
Response: The Organization is acting upon different guidance it has received. As of the date this audit is released, the contract this finding addresses is currently scheduled to end on 08/30/2025. NFFCMH will continue our current practice through the end of the current contract, and will review any potential change to same with any renewal of this contract.