Audit 405911

Finding 2025-001: Significant Deficiency – Procurement Documentation and Suspension/Debarment Verification Federal Grantor: U.S Department of Health and Human Services Compliance Requirement: Procurement, Suspension and Debarment Condition: CFILC did not retain sufficient procurement documentation to support compliance for certain purchases tested. Specifically, documentation supporting the evaluation process, sole-source procurement justification, and SAM.gov verification for suspended and debarred parties was not available for review. Criteria: Federal procurement standards require non-federal entities to maintain records sufficient to detail the history of procurement transactions, including the rationale for the method of procurement, contractor selection, basis for contract price, and verification that vendors are not suspended or debarred from participating in federally funded programs. Cause: CFILC’s procurement record retention procedures did not ensure that procurement files consistently included documentation supporting bid analyses, sole-source determinations, procurement evaluations, and SAM.gov verification procedures. Effect: The lack of complete procurement documentation limits CFILC’s ability to demonstrate compliance with federal procurement requirements and may result in questioned costs or noncompliance findings. Recommendation: We recommend that CFILC strengthen procurement documentation and record retention procedures to ensure procurement files consistently include documentation supporting vendor evaluations, bid analyses, sole-source justifications, SAM.gov verification, and related procurement decision-making records. In addition, staff responsible for procurement activities should be trained on federal procurement documentation requirements to ensure compliance is adequately supported. Response: We concur with the finding and have strengthened our procurement documentation procedures.

Finding 2025-002: Significant Deficiency – Lack of Documentation of Quarterly Reporting Federal Grantor: U.S Department of Health and Human Services Compliance Requirement: Reporting Condition: CFILC indicated that quarterly reports were provided verbally on a timely basis, however, CFILC did not maintain documentation evidencing that the report was submitted within the required deadline. Criteria: Federal grant reporting requirements require non-federal entities to maintain adequate documentation supporting compliance with reporting requirements, including evidence that required financial and performance information was submitted timely and completely. Cause: CFILC’s reporting procedures did not ensure that evidence of timely submission was consistently retained and reviewed as part of the reporting process. Effect: The lack of retained evidence of timely submission limits the ability to demonstrate compliance with federal reporting requirements and may impair grantor oversight of program performance and compliance. Recommendation: We recommend that CFILC strengthen its reporting procedures to ensure all required reports are submitted timely and that documentation supporting timely submission is properly retained and reviewed. Response: We concur with the finding and have strengthened our reporting procedures.

Finding 2025-003: Significant Deficiency – SEFA reporting Federal grantor: All Federal Programs Condition: The SEFA was not complete and contained reporting errors. Specifically, the grant contract amendment numbers and award amounts reported in SEFA were inaccurate. Criteria: Per 2 CFR § 200.510(b), the SEFA must include a complete and accurate listing of federal awards expended during the fiscal year. Information reported in the SEFA should agree to supporting grant documentation and underlying accounting records. Cause: The issues appear to result from a lack of comprehensive review and reconciliation procedures during SEFA preparation. Effect: Inaccurate SEFA reporting results in noncompliance with Uniform Guidance requirements and increases the risk of errors in federal reporting, incorrect identification of federal awards, and inaccurate major program determination. Recommendation: CFILC should strengthen internal controls over SEFA preparation by implementing a formal review and reconciliation process to verify grant contract amendment numbers, award amounts, and other key grant information to executed grant agreements and supporting documentation prior to issuance. Response: CFILC agrees with the finding and is implementing enhanced review procedures to ensure the accuracy and completeness of SEFA reporting going forward.