Criteria: In accordance with 2 CFR 200.206(d), non-federal entities are restricted from making contracts with parties that are debarred, suspended, or otherwise excluded from receiving federal awards or participating in federal awards. Condition: During our audit, we noted that the Agency did not review the debarment status of vendors prior to entering into a contract to purchase goods or services with those vendors. During the year ended June 30, 2024, the Agency spent approximately $190,000, with two vendors without performing a check on their debarment status. As part of the audit, we performed a debarment check and noted that neither vendor had been debarred. Cause: The Agency’s internal control system was not designed to incorporate debarment status checks for vendors with which the Agency is spending significant amounts of federal grant funding. Effect: The Agency could enter into a contract with a party that has been debarred, suspended, or otherwise excluded from receiving federal awards or participating in federal awards. Recommendation: We recommend that the Agency adopt an internal control policy that ensures that debarment status is checked prior to contracting with a party for the purchase of goods or services. Management’s response: Licking Valley Community Action Program, Inc. agrees with this finding. The executive director and finance officer will implement a debarment check with vendors with significant amounts of federal grant funding throughout the year to ensure debarment status. This will be added into the Internal Control Policy.
Finding 2024-003 Significant Deficiency – Internal Controls – SUSPENSION AND DEBARMENT ALN 10.555 Child Nutrition Program United States Department of Agriculture Passed through State of Louisiana Department of Education 2024 Funding Criteria: In accordance with 2 CFR Part 200.303(a), the School must establish, document, and maintain effective internal control over Federal awards that provide reasonable assurance that the recipient of subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, in accordance with 2 CFR 200.206(d), the School must comply with the government-wide suspension and debarment guidance in 2CFR Part 180 and individual Federal agency suspension and debarment requirements in title 2 of the Code of Federal Regulations. These requirements restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving Federal awards or participating in Federal awards. Condition: Documentation of proper review for suspension and debarment was not maintained for 3 of 3 vendors tested as required. Cause: The School did not maintain documentation of its review of vendors for suspension and debarment prior to contracting with them for work performed under Federal awards. Effect: Documentation of a review for suspension and debarment was not maintained for vendors with contracts under Federal awards. Questioned costs: None Recommendation: We recommend that the School maintain documentation of its review for suspension and debarment for all vendors with contracts under Federal awards. Management Response: See corrective action plan at page 38.
Criteria: In accordance with 2 CFR 200.206(d), non-federal entities are restricted from making contracts with parties that are debarred, suspended, or otherwise excluded from receiving federal awards or participating in federal awards. Condition: During our audit, we noted that the Agency did not review the debarment status of vendors prior to entering into a contract to purchase goods or services with those vendors. During the year ended June 30, 2024, the Agency spent approximately $190,000, with two vendors without performing a check on their debarment status. As part of the audit, we performed a debarment check and noted that neither vendor had been debarred. Cause: The Agency’s internal control system was not designed to incorporate debarment status checks for vendors with which the Agency is spending significant amounts of federal grant funding. Effect: The Agency could enter into a contract with a party that has been debarred, suspended, or otherwise excluded from receiving federal awards or participating in federal awards. Recommendation: We recommend that the Agency adopt an internal control policy that ensures that debarment status is checked prior to contracting with a party for the purchase of goods or services. Management’s response: Licking Valley Community Action Program, Inc. agrees with this finding. The executive director and finance officer will implement a debarment check with vendors with significant amounts of federal grant funding throughout the year to ensure debarment status. This will be added into the Internal Control Policy.
Finding 2024-003 Significant Deficiency – Internal Controls – SUSPENSION AND DEBARMENT ALN 10.555 Child Nutrition Program United States Department of Agriculture Passed through State of Louisiana Department of Education 2024 Funding Criteria: In accordance with 2 CFR Part 200.303(a), the School must establish, document, and maintain effective internal control over Federal awards that provide reasonable assurance that the recipient of subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, in accordance with 2 CFR 200.206(d), the School must comply with the government-wide suspension and debarment guidance in 2CFR Part 180 and individual Federal agency suspension and debarment requirements in title 2 of the Code of Federal Regulations. These requirements restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving Federal awards or participating in Federal awards. Condition: Documentation of proper review for suspension and debarment was not maintained for 3 of 3 vendors tested as required. Cause: The School did not maintain documentation of its review of vendors for suspension and debarment prior to contracting with them for work performed under Federal awards. Effect: Documentation of a review for suspension and debarment was not maintained for vendors with contracts under Federal awards. Questioned costs: None Recommendation: We recommend that the School maintain documentation of its review for suspension and debarment for all vendors with contracts under Federal awards. Management Response: See corrective action plan at page 38.
Program: Coronavirus State and Local Fiscal Recovery Funds ALN 21.027 Program Requirement: Procurement Criteria: Pursuant to 2 CFR section 200.206 (d)(1), non-Federal entities are restricted from doing business with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition: Procurement files did not have written documentation of the College’s verification that vendors were not suspended or debarred or otherwise excluded from federal programs. Context: Three out of three procurement files did not have documentation of verification that the vendor was not debarred or suspended. Cause: The College failed to document in the file their verification that the vendor was not debarred or suspended. Effect: The College is not able to provide proper supporting documentation of compliance with the suspended or debarred requirements. Questioned Costs: No Repeat Finding: Yes Recommendation: The College needs to implement a review of process of procurement files to ensure that proper supporting documentation is obtained and included in the procurement files. Views of Responsible Officials: The College agrees with the recommendation and plans to develop a checklist to ensure compliance with the procurement requirements related to suspension and debarment.
Program: Coronavirus State and Local Fiscal Recovery Funds ALN 21.027 Program Requirement: Procurement Criteria: Pursuant to 2 CFR section 200.206 (d)(1), non-Federal entities are restricted from doing business with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition: Procurement files did not have written documentation of the College’s verification that vendors were not suspended or debarred or otherwise excluded from federal programs. Context: Three out of three procurement files did not have documentation of verification that the vendor was not debarred or suspended. Cause: The College failed to document in the file their verification that the vendor was not debarred or suspended. Effect: The College is not able to provide proper supporting documentation of compliance with the suspended or debarred requirements. Questioned Costs: No Repeat Finding: Yes Recommendation: The College needs to implement a review of process of procurement files to ensure that proper supporting documentation is obtained and included in the procurement files. Views of Responsible Officials: The College agrees with the recommendation and plans to develop a checklist to ensure compliance with the procurement requirements related to suspension and debarment.