Finding ref number: 2022-003Finding caption:The City?s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements.Name, address, and telephone of City contact person:Debra Rhinehart, HSD Interim Federal Grants Mgt Unit Manager, 206.684.0574Theresa Ge...
Finding ref number: 2022-003Finding caption:The City?s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements.Name, address, and telephone of City contact person:Debra Rhinehart, HSD Interim Federal Grants Mgt Unit Manager, 206.684.0574Theresa George, HSD Accounting Manager, 206.798.3360Corrective action the auditee plans to take in response to the finding:HSD Response:HSD as the CDBG administrator, in collaboration with its contracted consultant support TDA consulting, will complete the following steps to support the resolution of this finding noting internal controls were inadequate for ensuring staff verified the suspension and debarment status of sub-recipients within the Office of Housing.HSD will conduct a thorough review of all existing MOAs with our recipients to ensure that the language pertaining to the verification and the documenting of the suspension and debarment status of sub-recipients is clear, consistent, and aligned with federal and state regulations. HSD will also assure staff responsible for administering CBDG funds and other federal funds are oriented to the importance of adhering to the debarment verification requirements outlined in the MOAs. HSD will encourage its city partners receiving these funds to work with other city partners to adopt standardized procedures for the verification and documentation of sub-recipient suspension and debarment status.Office of Housing Response:The Office of Housing will implement and communicate the following procedures: For all contracts expected to receive $25,000 or more in federal funds, the program staff person initiating the contract will first search the SAM website to verify that: the agency is registered, the agency?s registration status is active, and the agency does not have any active exclusions such as debarment or suspension. This status will be double-checked by the future Senior Contracts Specialist position before any contract is finalized.Anticipated date to complete the corrective action:The Office of Housing will hold a meeting of all relevant managers and supervisors on 9/26/23, during which all will be notified (or reminded) of the procedures described above. When the new Senior Contracts Specialist position is hired (estimated by 12/31/23), one of their first tasks will be to write and distribute a comprehensive contracts policy for the Office of Housing, which will include the procedures described above.