Audit 371258

Criteria: 2024 Compliance Supplement stated that the non-federal entity must meet the general procurement standards in 2 CFR section 200.318(a), which indicated that the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. Condition/Context: As a result of our audit procedures, we noted that Eden's current purchasing (procurement) policy does not include the elements required by the Uniform Guidance. In particular, the policy should address the procurement methods outlined in the procurement claw (i.e. micro-purchases, small purchases, competitive bidding, etc.). Repeat Finding from Prior Year(s): No Cause and Effect: This issue arose from Eden’s limited understanding of the Uniform Guidance’s procurement requirements, which contributed to non-compliance with program requirements. Questioned Cost: None Recommendation: We recommend that management revisit its procurement policies to incorporate the necessary elements required by the Uniform Guidance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding that the agency did not have policies for Procurement or Suspension and Debarment. The agency intends to adopt a procurement policy and procedures that meets the general procurement standards in 2 CFR section 200.318(a) and the State of California. The agency is also creating policies and procedures to ensure vendors are not suspended or debarred from work on federally funded projects.

Criteria: 2024 Compliance Supplement and 2 CFR 200.303(a) stated that the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. In addition, the eligibility of those individuals who were admitted to the program should be determined by (1) obtaining applications that contain all the information needed to determine eligibility, including diagnosis, documentation of housing need, income, rent, and order of selection; and (2) obtaining third party verifications or documentation of expected income, assets, unusual medical expenses, and any other pertinent information., Condition/Context: As a result of our audit procedures over 9 cases selected for testing, we noted 9 instances where management did not have a review process in place for the intake forms prepared by an employee during the eligibility process. Additionally, in 6 of the 9 instances, some of the information needed to determine eligibility was not retained. This missing information included, but was not limited to, income/employment verification and letter of diagnosis. Repeat Finding from Prior Year(s): No Cause and Effect: Eden did not have adequate controls in place to ensure that eligibility intake forms were reviewed and that the necessary information for eligibility determination was retained. Questioned Cost: None Recommendation: We recommend that management implement policies and procedures requiring eligibility intake forms to be reviewed by appropriate personnel to ensure all required documents are requested and retained in the case file. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding that the internal controls required for this program had material weaknesses. To ensure proper program management, program staff have created appropriate procedures and processes to demonstrate internal controls. These include a manager review of potential clients, a checklist for ensuring that the program collects and maintains required records, and a procedure for collecting and storing third-party documentation for client program intake/eligibility, diagnosis, and income.