2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-004 Internal Controls over Compliance and Compliance with Period of Performance Compliance Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720FDA20GR00287 July 10, 2020 through November 15, 2021 720FDA20GR00216 July 15, 2020 through January 14, 2021 72DFFP20GR00010 March 1, 2020 through May 31, 2021 Criteria or Specific Requirement: In accordance with 2 CFR ?200.309, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award as required by ?200.344(b). When used in connection with a non-Federal entity?s utilization of funds under a Federal award, ?obligations? means orders placed for property, services, contracts, and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period as described in ?200.71. Condition: During our testing of the period of performance compliance requirement, we selected twenty-five expense samples specifically for grants that began or ended during the year ended September 30, 2022. We also selected nine grant awards with a grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. Out of the twenty-five samples selected for testing, we identified one expense sample in the amount of $1,029 that was incurred after the end of the period of performance. Out of the nine grant awards selected for testing, we noted that expenses were either charged and/or reclassified to two grant awards that already expired prior to fiscal year 2022. Grant awards 720FDA20GR00216 and 72DFFP20GR00010 were charged $100,382 and $130,610, respectively, for the year ended September 30, 2022 even though these grants already concluded per their grant terms, prior to fiscal year 2022. The amount of $100,382 was an overspending of an expired grant which was reclassified in fiscal year 2021 and inadvertently reversed back in the fiscal year 2022 with no impact in financial reporting to the donor. The amount of $130,610 was reclassified to grant award 72DFFP20GR00010 from grant award 72DFFP18GR00019 during fiscal year 2022. It was also noted during this testing that CRS?s new ERP system as currently configured does not restrict recording of expenses and adjustments to grant awards that already expired at the sub-ledger levels where the transactions are initiated. Questioned Costs: Expenditures incurred after the end of the period of performance totaled $1,029 and are considered to be known questioned costs. The amount of $100,382 noted above was not claimed from the federal grantor but it should have not been included in the schedule of expenditures of federal awards for the year ended September 30, 2022. Context: BDO?s testing of the period of performance compliance requirement was performed by examining whether the expenses selected specifically for grants that began or ended during the fiscal year 2022 were incurred within the proper period of performance of the award. The total amount of the twenty-five expense items selected for testing was $194,527 out of the total population of $10,470,570. BDO also performed specific period of performance procedures on the nine grant awards with grant period end date prior to fiscal year 2022 that had expenses charged during the year ended September 30, 2022. The total amount of expenditures for the nine grant awards selected for testing was $1,311,595. Samples were selected using a non-statistical approach. Cause: CRS management has documented procedures in place to review expenditures; however, those procedures were not performed to a level of detail to identify expenses that were incurred outside the period of the award. The control procedures are primarily manual as the new ERP system as currently configured does not have capability to restrict recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Effect: While the known questioned costs that resulted from the conditions identified above were not material to the major program, the lack of adherence to the established internal control procedures around the period of performance of the award can lead to noncompliance with federal statutes, regulations, and the provisions of the grant agreements. This could ultimately result in additional disallowed costs for the major program. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management revisit and consider revising their internal procedures around detecting expenditures incurred outside of the period of performance of the awards as well as for ensuring that expenses are recorded in the appropriate fiscal year from an accrual basis perspective. We also recommend management work towards enhancing or determining a modification of the ERP system?s capability to restrict the recording of expenses and adjustments to expired awards at the sub-ledger levels where the transactions are initiated. Views of Responsible Officials: CRS management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.
2022-003 Internal Controls over Compliance and Compliance with Procurement, Suspension and Debarment Requirement Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Grant Award Number(s): Direct Award Number Award Period 720BHA21GR00063 March 29, 2021 through April 27, 2023 7200AA18CA00060 September 28, 2018 through September 27, 2025 72061318CA00001 January 9, 2018 through December 31, 2022 Criteria or Specific Requirement: In accordance with 2 CFR ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, ?200.318(i) states that the non-federal entity must maintain records sufficient to detail the history of the procurement. These records are required to include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In accordance with ?200.213 and ?180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Non-federal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with ?180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under ?180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified four procurement samples out of a total of forty procurement samples tested wherein management was unable to provide supporting documentation whether the suspension and debarment checks were performed prior to entering into contracts with the vendors. For two of the four procurement samples, CRS had previously contracted with the vendor and performed the suspension and debarment checks prior to those contracts. However, management was not able to provide evidence that they performed an updated suspension or debarment check when entering the new covered transaction, as required. Management subsequently checked that none of the vendors were suspended or debarred. However, the internal controls in place were not functioning as intended to ensure that procurement files are maintained, and suspension and debarment checks are performed prior to entering a new covered transaction. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. Cause: CRS personnel did not adhere to CRS?s documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a new covered transaction. Effect: Failure to timely verify that a vendor is not suspended or debarred could result in transactions involving unreasonable costs or result in unintentionally entering into a contract with an entity that is barred from performing work for the Federal government. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that suspension and debarment regulations are followed. We also recommend management ensure all required procurement documentation is maintained in conjunction with its document retention policy. Views of Responsible Officials: As noted by BDO in its description above, CRS had previously contracted three (3) of the four (4) identified vendors on previous covered transactions. Only one (1) of the vendors had not been subject to review via System for Award Management (SAM) prior to contracting/engagement. Management notes that the total comprehensive checks executed against major watchlists (including SAM.gov) in CRS totaled 23,212 (unaudited) in FY 2022 alone. While management agrees with BDO?s assessment of the samples, it should be noted CRS is strongly committed to compliance with applicable suspension and debarment regulations.