Audit 387687

Finding 2024-001 Suspension and Debarment and U.S. Government Regulations on Terrorism Information on the Federal Programs: Assistance Listing Numbers 94.006, 93.495, 14.252. Criteria: CFR 200.213 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Additionally, as outlined in each award, recipients of U.S. Government funds must adhere to the United States Government’s requirements on screening all potential vendors, suppliers, subcontractors/ grantees and employees against the United States Department of State’s Terrorism watch list. The screening of all potential vendors, suppliers, subcontractors/ grantees and employees must be documented in writing. Condition: CASA did not provide documentation to support its screenings for its potential and current vendors, suppliers, contractors, employees, etc. that were paid with Federal funds. Cause: CASA did not have a procedure in place to ensure all required screenings are performed and documentation to support the screening is maintained. During our audit, we inquired of evidence of such a process, and CASA was unable to provide support with respect to this area. Effect or Potential Effect: CASA could make payments to an entity or individual that has been debarred or suspended by the US Government; such costs would be disallowed, and CASA could face consequences for lack of compliance. Questioned Costs: None noted. Context: The absence of documented SAM verification creates a compliance gap and exposes CASA to the risk of engaging with suspended or debarred parties. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend CASA develop a policy of how screenings will be performed and how documentation will be maintained in order to demonstrate compliance with Government regulations. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.

Finding 2024-002 Noncompliance with 2 CFR 200.512(l) – Reporting Package Submission Criteria: Per 2 CFR §200.512(a), the auditee must submit the Data Collection Form (SF-SAC) and the reporting package to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Condition: CASA did not submit the required Data Collection Form (DCF) and reporting package to the FAC within the required timeframe for the year ended June 30, 2023. Cause: Due to staff turnover and delays in the completion of the June 30, 2023 audit. Effect: Late filing may impair the Federal Government’s ability to timely evaluate the financial and compliance performance of CASA and may affect eligibility for future Federal funding. Questioned Costs: None noted. Context: The auditor’s report was finalized after the required Data Collection Form (DCF) and reporting package to the FAC Federal due date. Identification as a Repeat Finding: See finding 2023-001. Recommendation: CASA should implement internal controls to ensure timely completion of the Uniform Guidance Audit and submission of the Data Collection Form and the reporting package, including monitoring deadlines and assigning responsibility for compliance.