2022 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0911L3T002002- FY22, PA0950L3T002001- FY22, and PA0758L3T002005- FY22 Pass-Through Agency: City of Philadelphia Office of Homeless Services Pass-Through Number(s): 21-20457, 21-20482, and 21-20455 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: During our audit, we noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization?s conflict of interest policy and the requirements of Uniform Guidance. Questioned costs: None Context: During our audit, we noted one instance where a vendor was contracted by the Organization to provide services throughout the year, however, the vendor was in violation of the Organization?s conflict of interest policy due to a relationship discovered subsequent to the fiscal year. The vendor was paid a total of $174,050 for services rendered during the period July 1, 2021 through June 30, 2022, of which $35,600 was charged to, and reimbursed by HUD, either directly or indirectly through passthrough funds from the City of Philadelphia Office of Supporting Housing. The remaining $138,450 was charged to various other city of Philadelphia funded contracts. Cause: The Organization had procured this vendor for services and was unaware the vendor had a relationship that caused a breach in the conflict-of-interest policy. The conflict was not disclosed. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to monitor new and potential contractors to determine whether a conflict of interest exists. Views of responsible officials: There is no disagreement with the audit finding. See attached corrective action plan.
2022 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0911L3T002002- FY22, PA0950L3T002001- FY22, and PA0758L3T002005- FY22 Pass-Through Agency: City of Philadelphia Office of Homeless Services Pass-Through Number(s): 21-20457, 21-20482, and 21-20455 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: During our audit, we noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization?s conflict of interest policy and the requirements of Uniform Guidance. Questioned costs: None Context: During our audit, we noted one instance where a vendor was contracted by the Organization to provide services throughout the year, however, the vendor was in violation of the Organization?s conflict of interest policy due to a relationship discovered subsequent to the fiscal year. The vendor was paid a total of $174,050 for services rendered during the period July 1, 2021 through June 30, 2022, of which $35,600 was charged to, and reimbursed by HUD, either directly or indirectly through passthrough funds from the City of Philadelphia Office of Supporting Housing. The remaining $138,450 was charged to various other city of Philadelphia funded contracts. Cause: The Organization had procured this vendor for services and was unaware the vendor had a relationship that caused a breach in the conflict-of-interest policy. The conflict was not disclosed. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to monitor new and potential contractors to determine whether a conflict of interest exists. Views of responsible officials: There is no disagreement with the audit finding. See attached corrective action plan.
2022 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0911L3T002002- FY22, PA0950L3T002001- FY22, and PA0758L3T002005- FY22 Pass-Through Agency: City of Philadelphia Office of Homeless Services Pass-Through Number(s): 21-20457, 21-20482, and 21-20455 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: During our audit, we noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization?s conflict of interest policy and the requirements of Uniform Guidance. Questioned costs: None Context: During our audit, we noted one instance where a vendor was contracted by the Organization to provide services throughout the year, however, the vendor was in violation of the Organization?s conflict of interest policy due to a relationship discovered subsequent to the fiscal year. The vendor was paid a total of $174,050 for services rendered during the period July 1, 2021 through June 30, 2022, of which $35,600 was charged to, and reimbursed by HUD, either directly or indirectly through passthrough funds from the City of Philadelphia Office of Supporting Housing. The remaining $138,450 was charged to various other city of Philadelphia funded contracts. Cause: The Organization had procured this vendor for services and was unaware the vendor had a relationship that caused a breach in the conflict-of-interest policy. The conflict was not disclosed. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to monitor new and potential contractors to determine whether a conflict of interest exists. Views of responsible officials: There is no disagreement with the audit finding. See attached corrective action plan.
2022 ? 002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: PA0911L3T002002- FY22, PA0950L3T002001- FY22, and PA0758L3T002005- FY22 Pass-Through Agency: City of Philadelphia Office of Homeless Services Pass-Through Number(s): 21-20457, 21-20482, and 21-20455 Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have internal controls designed to ensure compliance with those provisions. 2 CFR section 200.318(c) and 48 CFR sections 52.203-13 and 52.303-16 requires entities to maintain standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Condition: During our audit, we noted the Organization did not have adequate internal controls designed to ensure all vendors were compliant with the Organization?s conflict of interest policy and the requirements of Uniform Guidance. Questioned costs: None Context: During our audit, we noted one instance where a vendor was contracted by the Organization to provide services throughout the year, however, the vendor was in violation of the Organization?s conflict of interest policy due to a relationship discovered subsequent to the fiscal year. The vendor was paid a total of $174,050 for services rendered during the period July 1, 2021 through June 30, 2022, of which $35,600 was charged to, and reimbursed by HUD, either directly or indirectly through passthrough funds from the City of Philadelphia Office of Supporting Housing. The remaining $138,450 was charged to various other city of Philadelphia funded contracts. Cause: The Organization had procured this vendor for services and was unaware the vendor had a relationship that caused a breach in the conflict-of-interest policy. The conflict was not disclosed. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to monitor new and potential contractors to determine whether a conflict of interest exists. Views of responsible officials: There is no disagreement with the audit finding. See attached corrective action plan.