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May 27, 2025 U.S. Department of Treasury Tech Goes Home Incorporated respectfully submits the following corrective action plan for the fiscal year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs 50 Washington Street Westborough, Massachusetts 01581 Audit peri...
May 27, 2025 U.S. Department of Treasury Tech Goes Home Incorporated respectfully submits the following corrective action plan for the fiscal year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs 50 Washington Street Westborough, Massachusetts 01581 Audit period: The finding from the December 31, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY AND MATERIAL INSTANCE OF NONCOMPLIANCE DEPARTMENT OF TREASURY Passed through Massachusetts Technology Park Corporation d/b/a Massachusetts Technology Collaboration 2024-001 Procurement Policy and Procedures COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, assistance listing number 21.027. Recommendation: Management should develop and implement a procurement policy that aligns with the requirements set forth in 2 CFR §§ 200.317–200.326 of the Uniform Guidance. Action Taken: Management acknowledges the finding and concurs with the recommendation. TGH is in the process of developing and formalizing a comprehensive procurement policy that complies with the procurement standards outlined in 2 CFR §§ 200.317–200.326 of the Uniform Guidance. The policy will address key areas such as allowable procurement methods, competition requirements, contract oversight, and verification against the federal suspension and debarment list. Management anticipates that the procurement policy will be reviewed and approved by the appropriate oversight body by June 30, 2025, and staff will receive training on its implementation shortly thereafter. TGH is committed to strengthening internal controls over procurement to ensure continued compliance with federal requirements. If the U.S. Department of Treasury Massachusetts Technology Park Corporation d/b/a Massachusetts Technology Collaboration has questions regarding this plan, please email Dahlia Bousaid Cox at dahlia@techgoeshome.org. Sincerely yours, Dahlia Bousaid Cox Interim Chief Executive Officer Tech Goes Home Incorporated
Finding 571508 (2024-002)
Significant Deficiency 2024
Going forward the Organization will ensure there is documentation that verification of vendors are not suppressed or debarred.
Going forward the Organization will ensure there is documentation that verification of vendors are not suppressed or debarred.
Condition: The City did not have controls in place surrounding the review of contracts and bid documents and omitted the Build America Buy America clause. Planned Corrective Action: While the City did have sufficient internal policy in place to ensure compliance with 2 CFR 200 procurement requiremen...
Condition: The City did not have controls in place surrounding the review of contracts and bid documents and omitted the Build America Buy America clause. Planned Corrective Action: While the City did have sufficient internal policy in place to ensure compliance with 2 CFR 200 procurement requirements, the City failed to follow such procedures, despite compliance in practice. To address this, the City will revise both its Grants Management and Procurement Administrative Regulations to ensure that all required federal provisions are explicitly included in all applicable solicitations and contracts. Updated procedures will reinforce alignment between policy and practice. Contact person responsible for corrective action: Grant Accountant and Accounting Manager Anticipated Completion Date: 7/31/2025
Finding 571437 (2024-003)
Material Weakness 2024
FINDING 2024-03 Finding Subject: Water and Waste Disposal System for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Beth Jones Contact Phone Number and Email Address: 812 723-2739, clerk@paoli.in.gov Views of Responsible Officials: We c...
FINDING 2024-03 Finding Subject: Water and Waste Disposal System for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Beth Jones Contact Phone Number and Email Address: 812 723-2739, clerk@paoli.in.gov Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The Clerk Treasurer will work with the council and town attorney to make sure we are following the procurement policy and that we are compliant with the Federal and State guidelines. If a new project or a current project is being extended to a significant amount; during a council meeting, we will state that we are retaining a certain vendor for the project and explain why we are using that vendor. Anticipated Completion Date: August 1, 2025
The District will modify the federal procurement language existing in its current policy in accordance with 2 CFR 200.
The District will modify the federal procurement language existing in its current policy in accordance with 2 CFR 200.
CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2024 AUDITOR FINDING: 2024-004 Procurement and Suspension & Debarment Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds In accordance with 2 CFR 200.318, non-Federal entities must have and use documented p...
CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2024 AUDITOR FINDING: 2024-004 Procurement and Suspension & Debarment Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds In accordance with 2 CFR 200.318, non-Federal entities must have and use documented procurement procedures, consistent with State and local regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. The Organization's procurement policy requires obtaining three competitive bids for purchases in excess of $5,000 before purchase order is placed. In addition, it states that CFR 200's procurement standards are the guiding legislation. The Organization did not have adequate documentation to support the Organizations procurement decisions and did not have adequate internal controls in place which resulted in a purchase without adherence to the Organization's own procurement policies and the Uniform Guidance. CLIENT PLANNED ACTION: 1. SummitStone will review and align its procurement policy with Uniform Guidance compliance requirements for procurement records per 2 CFR 200.318 (i) Procurement records as well as 2 CFR § 200.214 Suspension and debarment requirements. 2. SummitStone will provide the necessary training on Uniform Guidance procurement compliance requirements to its procurement personnel and other authorized purchasers within the organization. 3. SummitStone will update its purchasing procedures and record keeping thereof, to ensure that competitive bids are obtained prior to contract / purchase order issuance / q CLIENT RESPONSIBLE PARTY: John Dowling, Chief Financial Officer Sarah Bystrom, Director of Compliance COMPLETION DATE: September 30, 2025
View Audit 362266 Questioned Costs: $1
Finding 2024-002 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CPFFN0190, 2024 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding Summary: Du...
Finding 2024-002 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CPFFN0190, 2024 COVID-19 – Coronavirus Capital Projects Fund Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding Summary: During the course of the engagement, it was identified that the Cooperative’s written policy did not address the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: Denne’ Smith, Chief Financial Officer Corrective Action Plan: The Cooperative will update its written policy to include the requirements of 2 CFR sections 200.318 through 200.326. Anticipated Completion Date: June 30, 2025
In FY24, the Food Service Department piloted a recurring “Pizza Friday” program as part of its student lunch offerings. The District utilized Domino’s due to its demonstrated reliability, familiarity with school food service requirements, and consistent performance. The total annual cost of the purc...
In FY24, the Food Service Department piloted a recurring “Pizza Friday” program as part of its student lunch offerings. The District utilized Domino’s due to its demonstrated reliability, familiarity with school food service requirements, and consistent performance. The total annual cost of the purchases exceeded the federal micro-purchase threshold of $5,000. As a result of this finding, the District has updated its internal procurement practice to ensure multiple quotes and/or participation in approved consortiums and purchasing co-ops for services anticipated to exceed this cost. Additionally, the Board has updated policy to increase the threshold from $5,000 to $10,000.
Finding 571139 (2024-001)
Significant Deficiency 2024
Single Audit Finding: 2024-001 Federal Agency Name: Colorado Department of Transportation  Program Name: Formula Grants for Rural Areas and Tribal Transit CFDA #: 20.509 Finding Summary: Procurement and Suspension and Debarment, Significant Deficiency in Internal Control over Compliance. Responsi...
Single Audit Finding: 2024-001 Federal Agency Name: Colorado Department of Transportation  Program Name: Formula Grants for Rural Areas and Tribal Transit CFDA #: 20.509 Finding Summary: Procurement and Suspension and Debarment, Significant Deficiency in Internal Control over Compliance. Responsible Individuals: Heidi Wise - Acting Deputy Chief Financial Officer, Marisa Rupp - Grants and Contracts Specialist, Bob Grogan - Purchasing Manager, Sarah Hill - Transportation Director, Calia Kimball - Transportation Specialist Corrective Action Plan: The City of Durango concurs with this finding and has planned steps to strengthen its internal controls related to procurement and suspension and debarment. In response, the City will implement a formal, standardized procurement process for these services, in coordination with the Risk Management division. This process will be adopted on a citywide basis and occur annually to ensure consistent application and compliance with federal and state regulations. To further reinforce compliance and oversight, a citywide Request for Proposals (RFP) for these types of services will be initiated in the coming weeks. The Transportation Director will coordinate with the Safety/Risk Administrator to lead this effort. Additionally, the City has scheduled an organization-wide training session to reinforce key procurement policies and best practices, with a focus on suspension and debarment compliance. Additionally, a new Purchasing Policy was adopted in early 2025, which includes enhanced documentation and verification requirements, specifically addressing procurement documentation - suspension and debarment checks for vendors. These measures are designed to ensure compliance with applicable procurement standards and reduce the risk of future deficiencies. Ongoing training and monitoring will be conducted to verify continued adherence and to promote accountability across all departments. Anticipated Completion Date: Implementation activities for the procurement in question, will begin in the coming weeks, with the RFP process and staff training scheduled for completion in the third quarter of 2025.
Views of Responsible Officials: FASEB acknowledges the findings identified by the audit regarding procurement and suspension and debarment. We recognize the importance of maintaining adequate records of the procurement process to ensure compliance with federal regulations and to promote transparency...
Views of Responsible Officials: FASEB acknowledges the findings identified by the audit regarding procurement and suspension and debarment. We recognize the importance of maintaining adequate records of the procurement process to ensure compliance with federal regulations and to promote transparency and accountability in our operations. Managements Response to Audit Finding on inadequate recording of procurement history or justification: 1. Review and Update Procurement Policies:  We will conduct a thorough review of our current procurement policies and procedures to identify any gaps or areas requiring improvement.  Updates will be made to ensure that our procurement policies align with federal regulations, including those related to suspension and debarment. 2. Training for Staff:  We will provide comprehensive training for all staff involved in the procurement process to ensure they understand the updated policies and the importance of maintaining proper records.  Training will include guidance on documentation requirements, vendor selection criteria, and compliance with federal regulations. 3. Implementation of Record-Keeping System:  We will implement a centralized, secure, and user-friendly record-keeping system to document all procurement activities.  This system will include templates and checklists to guide staff in capturing all necessary information, including vendor selection, bid evaluations, contract awards, and verification of suspension and debarment status. 4. Regular Monitoring and Audits:  We will establish a schedule for regular internal audits of the procurement process to ensure ongoing compliance and to identify any potential issues promptly.  Findings from these audits will be reviewed by senior management, and corrective actions will be taken as needed. 5. Vendor Verification:  We will enhance our procedures for verifying the suspension and debarment status of potential vendors before awarding contracts.  This verification process will be documented and retained as part of the procurement records. Conclusion: FASEB is committed to addressing the findings related to procurement and suspension and debarment. We believe that the steps outlined in our corrective action plan will ensure compliance with Federal regulations and enhance the integrity and transparency of our procurement process. We appreciate the opportunity to improve our practices and will provide updates on our progress as requested.
COVID-19: Coronavirus State and Local Fiscal Recovery Funds: Workforce Innovation Grant – Assistance Listing No. 21.027 Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA ...
COVID-19: Coronavirus State and Local Fiscal Recovery Funds: Workforce Innovation Grant – Assistance Listing No. 21.027 Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization plans to review its procurement and suspension and debarment policies and asses necessary changes to be in accordance with Uniform Guidance going forward. Name(s) of the contact person(s) responsible for corrective action: Trent Henning, Executive Director, and Luke Smetters, Director of Operations Planned completion date for corrective action plan: December 31, 2025
SINGLE AUDIT FOR THE YEAR ENDED SEPTEMBER 30, 2024 CORRECTIVE ACTION PLAN FEDERAL AWARD FINDINGS - Fiscal Year 2024 Finding Number: 2024-001 Procurement Assistance Listing Number: 93.696 Assistance Listing Title: Certified Community Behavioral Health Clinics N ame of Federal Agency: Substance Abuse...
SINGLE AUDIT FOR THE YEAR ENDED SEPTEMBER 30, 2024 CORRECTIVE ACTION PLAN FEDERAL AWARD FINDINGS - Fiscal Year 2024 Finding Number: 2024-001 Procurement Assistance Listing Number: 93.696 Assistance Listing Title: Certified Community Behavioral Health Clinics N ame of Federal Agency: Substance Abuse and Mental Health Services Administration Federal Award Identification Number: H79SM089299 Fiscal Year of Initial Finding: 2024 • Name of the contact person: Tina Boyer, CFO • Corrective Action Plan: Management agrees with this recommendation. VBCMH management will review and update policies and procedures to ensure that allfederal requirements are followed. Anticipated Completion Date: Fiscal Year 2025
View Audit 361252 Questioned Costs: $1
FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: ...
FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $77,285 Prior Year Finding: FA 2023-001 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: Berrien will look at the current procedures for expenditures and make sure that every program is following the same protocols. We have a system in place to ensure that we can check suspension and debarment. Also, we have protocols in place to make sure all contracts are current. Estimated Completion Date: 9/30/2025 Contact Person: Jamie Taylor, Finance Director Telephone: 229-686-2081 Email: jamie.taylor@berrien.k12.ga.us
View Audit 361188 Questioned Costs: $1
- We now implemented a best practice to require that a contractor submitting a bid or sub awardees affirms that they are not debarred, suspended or otherwise ineligible for federal funding during contracting with IFPA. We save their email response and include the file in any future audits. - As a be...
- We now implemented a best practice to require that a contractor submitting a bid or sub awardees affirms that they are not debarred, suspended or otherwise ineligible for federal funding during contracting with IFPA. We save their email response and include the file in any future audits. - As a best practice, we will make every attempt to avoid sole-sourcing. In cases where solesourcing is unavoidable, we will document and file the sole-source justification of services to be procured from contractors or sub awardees in which it applies in the form of former contacts or otherwise written confirmation - As a result, we will draft and adopt a formal procurement policy.
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 In response to the finding related to non-compliance w...
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 In response to the finding related to non-compliance with procurement policies and procedures under Uniform Guidance 2 CFR §200.317 – §200.327, the Nebraska Urban Indian Health Coalition (NUIHC) is committed to ensuring full compliance with all applicable federal, state, local, and tribal procurement requirements. To address this finding and strengthen internal practices, the Coalition will implement the following corrective actions: 1. Procurement Policy Review with External Expertise: NUIHC has contracted with an external consultant with expertise in federal procurement regulations to assist in conducting a thorough review of the organization’s current procurement policies and procedures. This partnership will help ensure that all updates reflect the specific requirements of 2 CFR §200.317 – §200.327 and incorporate best practices in compliance, documentation, and oversight. 2. Update and Alignment of Procedures: With the support of the external contractor, NUIHC will update detailed procurement procedures to ensure they align with Uniform Guidance and any applicable state, local, or tribal procurement laws. Clear step-by-step procedures will be documented for each procurement method (e.g., micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals). 3. Ongoing Education and Training: NUIHC will implement a continued education and training program for all staff involved in procurement activities. In addition to the initial training on updated policies, refresher training will be offered annually and included as part of new employee onboarding. This will ensure sustained awareness of procurement responsibilities and regulatory compliance. 4. Internal Controls and Review Process: A formal internal control process will be implemented to verify compliance with updated procurement policies. This includes a procurement checklist, mandatory pre-approval protocols, and supporting documentation requirements for every procurement action. 5. Monitoring and Quarterly Compliance Checks: The Coalition will continue conducting quarterly internal audits of procurement activities to ensure adherence to policy, detect potential issues early, and implement timely corrective actions. Findings will be reported to leadership and the Board of Directors as part of ongoing compliance oversight. Timeline for Implementation: • External Consultant Engagement: Completed – May 2025 • Policy and Procedure Review: To be completed by July 31, 2025 • Initial Staff Training: To be conducted by August 15, 2025 • Internal Controls & Monitoring: To be fully implemented by August 31, 2025 • Ongoing Training and Quarterly Reviews: Begin Q3 2025 and continue thereafter Anticipated Full Compliance Date: August 31, 2025 Corrective Action Plan Finding 2024-005 – procurement Policy (Repeat Finding 2023-004) Responsible Party: Chief Financial Officer, Carlett Gregory
Condition: Prisma Health's written procurement policy and procedures are not compliant with the requirements of the Uniform Guidance (2 CFR Part 200). This includes the absence of a documented policy outlining the different procurement methods, related thresholds, necessary documentation, and steps ...
Condition: Prisma Health's written procurement policy and procedures are not compliant with the requirements of the Uniform Guidance (2 CFR Part 200). This includes the absence of a documented policy outlining the different procurement methods, related thresholds, necessary documentation, and steps to ensure full and open competition when using federal funds. Planned Corrective Action: Prisma Health acknowledges this finding and will develop and implement a Uniform Guidance compliant procurement policy within the next month. The policy will be reviewed and approved by the CFO, head of Procurement and representatives of the Grants team. Contact person responsible for corrective action: Matt Elsey, Executive Vice President and CFO Anticipated Completion Date: 7/31/2025
The District of Columbia Public Library (DCPL) concurs with the auditor’s findings and recommendations. Management acknowledges the finding regarding the procurement that was awarded prior to receiving the federal funding and the procurement did not fully adhere to the standards outlined in 2 CFR S...
The District of Columbia Public Library (DCPL) concurs with the auditor’s findings and recommendations. Management acknowledges the finding regarding the procurement that was awarded prior to receiving the federal funding and the procurement did not fully adhere to the standards outlined in 2 CFR Section 200. The Procurement was awarded under the District’s Municipal Regulations policies and procedures, we recognize that the 2 CFR Section 200 requirements are stricter. Effective June 12, 2025, DCPL will ensure that all Procurements comply with 2 CFR Section 200, including procurements awarded prior to receiving Federal funding. This includes: • Enhancing our internal review process and documentation to confirm the funding source and ensure Federal procurement regulations are followed. • Identify training for Procurement, Budget and Program Staff on Federal grant compliance and Procurements that fall under 2 CFR Section 200. Contact: Richard Reyes-Gavilan, Executive Director Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table
2024-009 Material Weakness and Material Noncompliance - Procurement and Suspension and Debarment Audit Finding: The Town did not have documentation to support following their purchasing policy for two out of six selections. The Town did not have documentation to support verification that four vendor...
2024-009 Material Weakness and Material Noncompliance - Procurement and Suspension and Debarment Audit Finding: The Town did not have documentation to support following their purchasing policy for two out of six selections. The Town did not have documentation to support verification that four vendors were not excluded from federal contracts due to debarment or suspension. Corrective Action Taken: Procurement findings: 1. Performance Foodservice had two (2) invoices dated May 2023 (FY23) paid in FY24. For FY23 the BOE had a contract with Performance. The invoices were for prior year. No purchases were made in FY24, only payment from FY23 purchases. BOE believes the purchasing policy was followed. 2. Sardilli Produce, had 3 PO’s entered in FY24. One PO was for $80,000 for yearly invoices. 58 invoices were charged to PO. Average invoice total was $1,289. The approved PO did not follow purchasing policy. Suspension and Debarment addressed in 2024-005. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226
View Audit 360711 Questioned Costs: $1
Person(s) responsible for corrective action: Lucy Yanez, Contract Specialist, Tracy Johnson, Accounts Payable, Tina Hurtado Controller, NWIFC staff and supervisors engaged in procurement and contracting. Management’s Response/Corrective Action Plan: The NWIFC implemented corrective measures relat...
Person(s) responsible for corrective action: Lucy Yanez, Contract Specialist, Tracy Johnson, Accounts Payable, Tina Hurtado Controller, NWIFC staff and supervisors engaged in procurement and contracting. Management’s Response/Corrective Action Plan: The NWIFC implemented corrective measures related to procurement in March of 2024. See FY23 Corrective Action Plan. However, the one procurement sample that was cited as not including “documentation of bidding, alternative price quotes or sole source documentation” contained a sole source justification that was developed before implementation of the FY23 Corrective Action Plan. The sole source justification was based on the specialized knowledge and specific expertise. Procurement samples for purchases or contracts after the implementation of the FY23 Corrective Action Plan, show compliance of adequate bidding, price quotes or sole source documentation consistent with 2 CFR 200. The NWIFC will continue to implement the FY23 Corrective Action Plan, by requiring NWIFC managers and their staff to be responsible for soliciting bids or developing sole source justifications for procurements and contracts consistent with 2 CFR 200. The Contract Specialist will ensure that bid solicitations and sole source justifications are properly documented and filed with each contract. Similarly, the audit noted that certain suspension and debarment samples selected, before the FY23 Corrective Action Plan was implemented in March 2024, lacked documentation of a suspension and debarment review prior to doing business with vendors. In response, the FY23 Corrective Action Plan, put into effect in March 2024, included measures to ensure that both new vendor and annual reviews are documented. The Accounts Payable department will continue to conduct suspension and debarment reviews for all new vendors before conducting business and perform annual reviews of all vendors, in line with the FY23 Corrective Action Plan. Anticipated completion date: Completed March 2024.
View Audit 360492 Questioned Costs: $1
Policy is being updated. The Maintenance Supervisor will obtain the required 3 bids that include wage rates and review them with the director before final decisions are made. Obtained bids will be kept on file for the period of time required for auditing purposes.
Policy is being updated. The Maintenance Supervisor will obtain the required 3 bids that include wage rates and review them with the director before final decisions are made. Obtained bids will be kept on file for the period of time required for auditing purposes.
Finding 567563 (2024-006)
Significant Deficiency 2024
Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Fe...
Finding 2024-006: Significant Deficiency- Procurement and Suspension, and Debarment - Internal Control over Procurement Documentation Program: Lead-Based Paint Hazard Reduction Grant Program Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities must meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document the history of procurements. During our audit, we noted that the City did not have the bidding documentation for one of our choices. Corrective Actions Taken: 1. Centralized Compliance Tracking: A comprehensive Grant Policy is in place to provide centralized oversight of grant management, including adherence to procurement procedures. 2. Strengthening Procurement Procedures: The Purchasing Department will provide ongoing training to departments on the City’s procurement processes and document retention policies to ensure consistent compliance. Contact: Malinda Figueroa, Purchasing Director, Anticipated Completion Date: December 2025
Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 2...
Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 29, 2026 A material weakness was issued related to internal control over suppliers under the UG audit. CFNI recognizes the need to comply with the procurement standards outlined in 2 CFR §§ 200.318-326, which require written policies addressing competition, conflicts of interest, procurement methods (micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive procurement), oversight, efforts to engage small and disadvantaged businesses, and procurement of recovered materials, among others. To address this deficiency, CFNI is committed to enhancing its documented procurement policies for procure-to-pay processes involving federal funds. The audit identified three instances out of 40 sampled where CFNI did not retain documentation verifying that suspension and debarment reviews were conducted during the onboarding of new suppliers. Although CFNI has an established vetting process, it recognizes the need for consistent documentation to evidence compliance. CFNI will implement formalized procedures to ensure all suspension and debarment reviews are documented and retained for audit purposes. CFNI engages a third-party contractor to monitor its supplier list against suspension and debarment databases. While the vendor provided a SOC 1 report, it did not specifically cover the suspension and debarment services provided. Additionally, CFNI did not conduct testing to validate the accuracy of the third-party's results. CFNI will revise its vendor management practices to ensure the SOC 1 reports cover the relevant services, and it will establish testing procedures to confirm the reliability of the vendor's outputs. Although CFNI utilizes two processes to monitor active suppliers against suspension and debarment lists—periodic PeopleSoft program checks and an annual review by a third-party vendor—no reconciliation was documented to confirm that the supplier lists provided to and received from the third party were complete and accurate. Additionally, no testing was conducted to validate the third party’s work. CFNI will implement a reconciliation process to verify the completeness and accuracy of supplier lists before and after third-party reviews. Furthermore, it will establish a sampling and testing procedure to validate the results provided by external vendors. CFNI will develop and implement a robust supplier management policy, incorporating requirements for procurement, suspension, and debarment reviews. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025
Finding 2024-003: TCFB was negligent in two areas for one of their purchases: No record of vendor verification that they were not suspended or disbarred and no WSDA prior approval for the purchase which was over $5,000. This was in violation of both their internal procedures and WSDA requirements. T...
Finding 2024-003: TCFB was negligent in two areas for one of their purchases: No record of vendor verification that they were not suspended or disbarred and no WSDA prior approval for the purchase which was over $5,000. This was in violation of both their internal procedures and WSDA requirements. The Problem: During testing the auditors noted that one instance of purchasing using WSDA funds was made without WSDA prior approval and proper documentation of suspension and debarment or WSDA prior approval. Established Standard: Organization must verify SAM registration and conduct suspension, and debarment checks prior to entering into any sub-agency agreement, contract, purchase, or equipment repair over $5,000. It is recommended that lead agency verifies, at least annually, that sub agencies and vendors are not suspended or debarred. Information about suspension and debarment checks is to be entered onto a spreadsheet of approved vendors. When the lead agency enters into a covered transaction with another agency or vendor, lead agency must verify that the entity with whom business is transacted is registered with SAM and is not excluded or disqualified. There are two methods for verification: A. Checking SAM.GOV exclusions (this method requires saving a copy of the verification search) B. Collecting a signed certification from the vendor. Actions to be taken: • Updated training of TCFB staff on the Policy/Procedures for procurements using WSDA funding. • Create step-by-step instructions for purchases using WSDA funding. • Effective October 1, 2024 WSDA’s threshold for preapprovals changed to $10,000. We will update our purchasing policy to reflect this change. Action Assignments: • Instruction checklist will be created by lead purchaser. • Lead purchaser will ensure that any purchases follow the Policy/Procedures for procurement. • Lead purchaser will be responsible for documenting SAM registration, Suspension and Debarment check, and WSDA pre-approvals. The documentation will consist of a copy of the exclusions page on SAM.GOV, as well as a spreadsheet of approved vendors with a date of last check. Timeline: • Instruction checklist for purchases using WSDA funds will be created by July 1st, 2025. • A spreadsheet has already been created to capture the information concerning Suspension and Debarment checks. A separate folder contains copies of each entities exclusion page from SAM.GOV. Verify Implementation: • In July 2025 Lead Purchaser will submit to the Executive Director: A. A copy of step-by-step instruction checklist. B. A copy of the spreadsheet with Suspension and Debarment checks C. Copies of exclusion pages from SAM.GOV Finance Dept. will verify invoice have received WSDA prior Approvals
Finding 566030 (2024-003)
Significant Deficiency 2024
2024-03: Lack of Procurement Policy Contact Person Heather Ferebee Corrective Action Plan A procurement policy will be developed and approved by the City Council. Completion Date 2025
2024-03: Lack of Procurement Policy Contact Person Heather Ferebee Corrective Action Plan A procurement policy will be developed and approved by the City Council. Completion Date 2025
Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Moving forward, the district will perform a cost/price analysis for...
Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Moving forward, the district will perform a cost/price analysis for procurement in excess of $250,000.
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