Audit 46383

Finding 2022-001 ? Internal Controls over Suspension and Debarment Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000. A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person. Condition: During fiscal year 2022, there was one payment to a subrecipient and seven financial assistance payments to local businesses that were equal to or greater than $25,000. There were no checks of suspension and debarment prior to payment for any of these transactions. Cause: During fiscal year 2022, there was turnover in the Fiscal Manager position and per inquiry, it appears the suspension and debarment checks were an oversight. Effect: In August 2022, a suspension and debarment check was performed for the subrecipient, whom was not identified as an excluded party. The remaining seven businesses were checked as a result of the audit fieldwork in November 2022 and were not on the excluded parties list. Although none of the entities were found to be on the excluded parties list, the risk of noncompliance is heightened if the suspension and debarment checks are not completed on the front-end prior to payment. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend the Organization review its current policies to ensure they are following the suspension and debarment provisions set forth in the Uniform Guidance, lessening the risk that payments are made to parties who may be excluded from receiving federal funds. View of Responsible Officials: In response to the above finding with regards to compliance with Subpart C of 2 CFR Part 180 requiring nonfederal entities to verify that the person/entity with whom they intend to do business is not excluded or disqualified if payments are expected to be equal to or greater than $25,000, the following action has been taken: When the weekly check run is being prepared, either before or after the purchase orders are entered but before checks are disbursed, each payee that might possibly meet the criteria described as having payments of $25,000 or more will be researched by the Fiscal Manager on SAM.GOV?s website for possible exclusions or debarments. The results will be saved and documented for audit purposes. Should a person/entity be found to have exclusions or results that would prohibit grant funds from being used, we would notify the person/entity that we would be unable to do business with them. If no results are to be found, this, too, shall be documented and further action will be required to obtain a certification from them or an amendment adding a clause or condition to the covered transaction. This change in procedure was put into effect upon notification of the finding. The fiscal policy handbook will be updated immediately to reflect the new procedure.

Finding 2022-001 ? Internal Controls over Suspension and Debarment Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000. A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person. Condition: During fiscal year 2022, there was one payment to a subrecipient and seven financial assistance payments to local businesses that were equal to or greater than $25,000. There were no checks of suspension and debarment prior to payment for any of these transactions. Cause: During fiscal year 2022, there was turnover in the Fiscal Manager position and per inquiry, it appears the suspension and debarment checks were an oversight. Effect: In August 2022, a suspension and debarment check was performed for the subrecipient, whom was not identified as an excluded party. The remaining seven businesses were checked as a result of the audit fieldwork in November 2022 and were not on the excluded parties list. Although none of the entities were found to be on the excluded parties list, the risk of noncompliance is heightened if the suspension and debarment checks are not completed on the front-end prior to payment. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend the Organization review its current policies to ensure they are following the suspension and debarment provisions set forth in the Uniform Guidance, lessening the risk that payments are made to parties who may be excluded from receiving federal funds. View of Responsible Officials: In response to the above finding with regards to compliance with Subpart C of 2 CFR Part 180 requiring nonfederal entities to verify that the person/entity with whom they intend to do business is not excluded or disqualified if payments are expected to be equal to or greater than $25,000, the following action has been taken: When the weekly check run is being prepared, either before or after the purchase orders are entered but before checks are disbursed, each payee that might possibly meet the criteria described as having payments of $25,000 or more will be researched by the Fiscal Manager on SAM.GOV?s website for possible exclusions or debarments. The results will be saved and documented for audit purposes. Should a person/entity be found to have exclusions or results that would prohibit grant funds from being used, we would notify the person/entity that we would be unable to do business with them. If no results are to be found, this, too, shall be documented and further action will be required to obtain a certification from them or an amendment adding a clause or condition to the covered transaction. This change in procedure was put into effect upon notification of the finding. The fiscal policy handbook will be updated immediately to reflect the new procedure.