Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Federal Award Number: NU50CK000556 Award Periods: January 1, 2024 – July 31, 2024 Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The organization did not document that SAM.gov was checked prior to entering into a contract with a vendor. Questioned Costs: None. Context: This condition impacted five of five transactions selected for testing. None of the entities transacted with were determined to be excluded parties per SAM.gov. Cause: Based on the timing of when the grant was received by the Organization (June 2024) and when the period of performance expired (July 2024), the Organization had extremely limited time to accomplish the program objectives. Thus, the organization did not maintain documentation that vendors were verified as not being suspended or debarred prior to entering into the transaction. Effect: The Organization could potentially entered into a transaction with an entity that has been suspended or debarred. Repeat Finding: No. Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Program Cluster Assistance Listing Number: 93.224/93.527 Federal Award Identification Number and Year: H80CS00758 / 2025 Award Period: April 1, 2024 to March 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria: Federal regulations (2 CFR §§ 200.212 and 200.318(h); 2 CFR § 180.300; 48 CFR § 52.209-6) require that entities entering into covered transactions with federal award recipients be verified as not debarred, suspended, or otherwise excluded from participation in federal programs. This verification must be performed annually and prior to entering into any transaction exceeding the applicable threshold. Condition: We identified one instance in which the agency did not perform timely suspension and debarment verification for a vendor prior to entering into a covered transaction. Questioned costs: None Context: The vendor in question had a long-standing relationship with the agency and was considered reputable by management. Due to this familiarity, verification procedures were not followed as required, resulting in a lapse in compliance. Cause: The agency relied on the vendors history and reputation, assuming compliance without conducting the required verification. Effect: The agencys failure to consistently perform timely suspension and debarment verifications resulted in noncompliance with federal procurement requirements. Although the vendor in question was ultimately eligible, without a reliable and documented verification process, the Agency risks unintentionally engaging with ineligible vendors in future transactions. Repeat Finding: No Recommendation: We recommend management implement suspension and debarment verification process for all covered vendors, regardless of their history or reputation, to ensure compliance with federal regulations. Views of the Responsible Officials and Planned Corrective Action: Management agrees with the finding and acknowledges that timely suspension and debarment verification was not consistently performed across all vendors. To address this deficiency, the agency is implementing a standardized process to ensure suspension and debarment checks are conducted prior to entering into any covered transaction, regardless of vendor history. This process will include documented verification steps, annual review protocols, and staff training to reinforce compliance with federal procurement regulations.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 21.027 & 93.623 Federal Program Titles: Coronavirus State and Local Fiscal Recovery Funds; Basic Center Grant Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318, General procurement standards, requires that non-Federal entities must have documented procurement procedures, consistent with State and local laws and regulations for the acquisition of property or services required under a federal award and subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.326. Condition: During our testing, we noted that the Organization’s procurement policy did not address all of the identified requirements in 2 CFR 200.318 through 200.326. Questioned Costs: None. Context: In our review of the current procurement policy, The Adams Group, LLC noted the following: • The policy did not include documented procedures for purchases above the simplified acquisition threshold ($250,000) in accordance with 2 CFR 200.320b. • The policy did not include documented procedures for the use and instances of noncompetitive procurement in accordance with 2 CFR 200.320c. • The policy did not include documented procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded as outlined in 2 CFR sections 200.212 and 200.318. • We also noted that the Organization did not verify that the entities with which it entered into contracts were not debarred, suspended, or otherwise excluded. Effect: The Organization’s procurement policy is not in compliance with general procurement standards, and proper verification procedures for potentially suspended or debarred entities were not performed. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the Organization update their procurement policy to address all requirements identified in 2 CFR 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 21.027 & 93.623 Federal Program Titles: Coronavirus State and Local Fiscal Recovery Funds; Basic Center Grant Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318, General procurement standards, requires that non-Federal entities must have documented procurement procedures, consistent with State and local laws and regulations for the acquisition of property or services required under a federal award and subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.326. Condition: During our testing, we noted that the Organization’s procurement policy did not address all of the identified requirements in 2 CFR 200.318 through 200.326. Questioned Costs: None. Context: In our review of the current procurement policy, The Adams Group, LLC noted the following: • The policy did not include documented procedures for purchases above the simplified acquisition threshold ($250,000) in accordance with 2 CFR 200.320b. • The policy did not include documented procedures for the use and instances of noncompetitive procurement in accordance with 2 CFR 200.320c. • The policy did not include documented procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded as outlined in 2 CFR sections 200.212 and 200.318. • We also noted that the Organization did not verify that the entities with which it entered into contracts were not debarred, suspended, or otherwise excluded. Effect: The Organization’s procurement policy is not in compliance with general procurement standards, and proper verification procedures for potentially suspended or debarred entities were not performed. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the Organization update their procurement policy to address all requirements identified in 2 CFR 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Criteria: 2 CFR sections 200.212 and 200.318(h); 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not retain the documentation of verification of vendors not suppressed or debarred prior to entering into a contract with the vendor. Cause: The Organization does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written procurement policy, if the Organization does not maintain sufficient documentation of procurement evaluations and decisions, the Organization's procurement practices will not comply with the Uniform Guidance. Recommendation: The Organization should retain formal documentation with regard to its procurement decisions. View of Responsible Officials: The Organization agrees with the finding, see corrective action plan.
Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 21.027 & 93.623 Federal Program Titles: Coronavirus State and Local Fiscal Recovery Funds; Basic Center Grant Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318, General procurement standards, requires that non-Federal entities must have documented procurement procedures, consistent with State and local laws and regulations for the acquisition of property or services required under a federal award and subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.326. Condition: During our testing, we noted that the Organization’s procurement policy did not address all of the identified requirements in 2 CFR 200.318 through 200.326. Questioned Costs: None. Context: In our review of the current procurement policy, The Adams Group, LLC noted the following: • The policy did not include documented procedures for purchases above the simplified acquisition threshold ($250,000) in accordance with 2 CFR 200.320b. • The policy did not include documented procedures for the use and instances of noncompetitive procurement in accordance with 2 CFR 200.320c. • The policy did not include documented procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded as outlined in 2 CFR sections 200.212 and 200.318. • We also noted that the Organization did not verify that the entities with which it entered into contracts were not debarred, suspended, or otherwise excluded. Effect: The Organization’s procurement policy is not in compliance with general procurement standards, and proper verification procedures for potentially suspended or debarred entities were not performed. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the Organization update their procurement policy to address all requirements identified in 2 CFR 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: U.S. Department of Health and Human Services Assistance Listing Numbers: 21.027 & 93.623 Federal Program Titles: Coronavirus State and Local Fiscal Recovery Funds; Basic Center Grant Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations 2 CFR 200.318, General procurement standards, requires that non-Federal entities must have documented procurement procedures, consistent with State and local laws and regulations for the acquisition of property or services required under a federal award and subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.326. Condition: During our testing, we noted that the Organization’s procurement policy did not address all of the identified requirements in 2 CFR 200.318 through 200.326. Questioned Costs: None. Context: In our review of the current procurement policy, The Adams Group, LLC noted the following: • The policy did not include documented procedures for purchases above the simplified acquisition threshold ($250,000) in accordance with 2 CFR 200.320b. • The policy did not include documented procedures for the use and instances of noncompetitive procurement in accordance with 2 CFR 200.320c. • The policy did not include documented procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded as outlined in 2 CFR sections 200.212 and 200.318. • We also noted that the Organization did not verify that the entities with which it entered into contracts were not debarred, suspended, or otherwise excluded. Effect: The Organization’s procurement policy is not in compliance with general procurement standards, and proper verification procedures for potentially suspended or debarred entities were not performed. Repeat Finding: This is a repeat finding. Recommendation: We recommend that the Organization update their procurement policy to address all requirements identified in 2 CFR 200.318 through 200.326. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: SC-110351 - 2024 SC-111132 - 2024 SC-110353 - 2024 SC-111134 - 2024 SC-110355 - 2024 SC-110349 - 2024 SC-111130 - 2024 Pass-Through Agency: Pierce County Pass-Through Number(s): LP9XHDGASCJ3 Award Period: SC-110351: 7/1/23-6/30/24 SC-111132: 7/1/24-6/30/25 SC-110353: 12/1/23-11/30/24 SC-111134: 12/1/24-11/30/25 SC-110355: 6/1/23-8/31/24 SC-110349: 5/1/23-4/30/24 SC-111130: 5/1/24-4/30/25 Type of finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303(a), recipients of federal funds must "establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Additionally, an entity is required to have policies and procedures in place for verifying the above requirements. Condition: During our suspension and debarment testing, CLA noted no suspension and debarment policy in place and no suspension and debarment check was performed over a covered transaction. Questioned costs: $7,442 of known questioned costs. Context: There was only one covered transaction subject to suspension and debarment check that had a contract amount exceeding $25,000 but only $7,442 was paid with federal program. However, no suspension and debarment check was performed. CLA elected to perform a SAM.gov check and noted that vendor (Locke System) is not debarred as of the date of the audit procedure. Cause: Share & Care House and Subsidiary lacks sufficient understanding of the compliance requirements surrounding covered transactions and suspension and debarment check requirements. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding caused Share & Care House and Subsidiary to be noncompliant with program requirements over suspension and debarment. Repeat finding: No. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.
Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: SC-110351 - 2024 SC-111132 - 2024 SC-110353 - 2024 SC-111134 - 2024 SC-110355 - 2024 SC-110349 - 2024 SC-111130 - 2024 Pass-Through Agency: Pierce County Pass-Through Number(s): LP9XHDGASCJ3 Award Period: SC-110351: 7/1/23-6/30/24 SC-111132: 7/1/24-6/30/25 SC-110353: 12/1/23-11/30/24 SC-111134: 12/1/24-11/30/25 SC-110355: 6/1/23-8/31/24 SC-110349: 5/1/23-4/30/24 SC-111130: 5/1/24-4/30/25 Type of finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303(a), recipients of federal funds must "establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Additionally, an entity is required to have policies and procedures in place for verifying the above requirements. Condition: During our suspension and debarment testing, CLA noted no suspension and debarment policy in place and no suspension and debarment check was performed over a covered transaction. Questioned costs: $7,442 of known questioned costs. Context: There was only one covered transaction subject to suspension and debarment check that had a contract amount exceeding $25,000 but only $7,442 was paid with federal program. However, no suspension and debarment check was performed. CLA elected to perform a SAM.gov check and noted that vendor (Locke System) is not debarred as of the date of the audit procedure. Cause: Share & Care House and Subsidiary lacks sufficient understanding of the compliance requirements surrounding covered transactions and suspension and debarment check requirements. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding caused Share & Care House and Subsidiary to be noncompliant with program requirements over suspension and debarment. Repeat finding: No. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.
Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: SC-110351 - 2024 SC-111132 - 2024 SC-110353 - 2024 SC-111134 - 2024 SC-110355 - 2024 SC-110349 - 2024 SC-111130 - 2024 Pass-Through Agency: Pierce County Pass-Through Number(s): LP9XHDGASCJ3 Award Period: SC-110351: 7/1/23-6/30/24 SC-111132: 7/1/24-6/30/25 SC-110353: 12/1/23-11/30/24 SC-111134: 12/1/24-11/30/25 SC-110355: 6/1/23-8/31/24 SC-110349: 5/1/23-4/30/24 SC-111130: 5/1/24-4/30/25 Type of finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303(a), recipients of federal funds must "establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Additionally, an entity is required to have policies and procedures in place for verifying the above requirements. Condition: During our suspension and debarment testing, CLA noted no suspension and debarment policy in place and no suspension and debarment check was performed over a covered transaction. Questioned costs: $7,442 of known questioned costs. Context: There was only one covered transaction subject to suspension and debarment check that had a contract amount exceeding $25,000 but only $7,442 was paid with federal program. However, no suspension and debarment check was performed. CLA elected to perform a SAM.gov check and noted that vendor (Locke System) is not debarred as of the date of the audit procedure. Cause: Share & Care House and Subsidiary lacks sufficient understanding of the compliance requirements surrounding covered transactions and suspension and debarment check requirements. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding caused Share & Care House and Subsidiary to be noncompliant with program requirements over suspension and debarment. Repeat finding: No. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.
Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: SC-110351 - 2024 SC-111132 - 2024 SC-110353 - 2024 SC-111134 - 2024 SC-110355 - 2024 SC-110349 - 2024 SC-111130 - 2024 Pass-Through Agency: Pierce County Pass-Through Number(s): LP9XHDGASCJ3 Award Period: SC-110351: 7/1/23-6/30/24 SC-111132: 7/1/24-6/30/25 SC-110353: 12/1/23-11/30/24 SC-111134: 12/1/24-11/30/25 SC-110355: 6/1/23-8/31/24 SC-110349: 5/1/23-4/30/24 SC-111130: 5/1/24-4/30/25 Type of finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303(a), recipients of federal funds must "establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Additionally, an entity is required to have policies and procedures in place for verifying the above requirements. Condition: During our suspension and debarment testing, CLA noted no suspension and debarment policy in place and no suspension and debarment check was performed over a covered transaction. Questioned costs: $7,442 of known questioned costs. Context: There was only one covered transaction subject to suspension and debarment check that had a contract amount exceeding $25,000 but only $7,442 was paid with federal program. However, no suspension and debarment check was performed. CLA elected to perform a SAM.gov check and noted that vendor (Locke System) is not debarred as of the date of the audit procedure. Cause: Share & Care House and Subsidiary lacks sufficient understanding of the compliance requirements surrounding covered transactions and suspension and debarment check requirements. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding caused Share & Care House and Subsidiary to be noncompliant with program requirements over suspension and debarment. Repeat finding: No. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.
Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: SC-110351 - 2024 SC-111132 - 2024 SC-110353 - 2024 SC-111134 - 2024 SC-110355 - 2024 SC-110349 - 2024 SC-111130 - 2024 Pass-Through Agency: Pierce County Pass-Through Number(s): LP9XHDGASCJ3 Award Period: SC-110351: 7/1/23-6/30/24 SC-111132: 7/1/24-6/30/25 SC-110353: 12/1/23-11/30/24 SC-111134: 12/1/24-11/30/25 SC-110355: 6/1/23-8/31/24 SC-110349: 5/1/23-4/30/24 SC-111130: 5/1/24-4/30/25 Type of finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303(a), recipients of federal funds must "establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Additionally, an entity is required to have policies and procedures in place for verifying the above requirements. Condition: During our suspension and debarment testing, CLA noted no suspension and debarment policy in place and no suspension and debarment check was performed over a covered transaction. Questioned costs: $7,442 of known questioned costs. Context: There was only one covered transaction subject to suspension and debarment check that had a contract amount exceeding $25,000 but only $7,442 was paid with federal program. However, no suspension and debarment check was performed. CLA elected to perform a SAM.gov check and noted that vendor (Locke System) is not debarred as of the date of the audit procedure. Cause: Share & Care House and Subsidiary lacks sufficient understanding of the compliance requirements surrounding covered transactions and suspension and debarment check requirements. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding caused Share & Care House and Subsidiary to be noncompliant with program requirements over suspension and debarment. Repeat finding: No. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.
Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: SC-110351 - 2024 SC-111132 - 2024 SC-110353 - 2024 SC-111134 - 2024 SC-110355 - 2024 SC-110349 - 2024 SC-111130 - 2024 Pass-Through Agency: Pierce County Pass-Through Number(s): LP9XHDGASCJ3 Award Period: SC-110351: 7/1/23-6/30/24 SC-111132: 7/1/24-6/30/25 SC-110353: 12/1/23-11/30/24 SC-111134: 12/1/24-11/30/25 SC-110355: 6/1/23-8/31/24 SC-110349: 5/1/23-4/30/24 SC-111130: 5/1/24-4/30/25 Type of finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303(a), recipients of federal funds must "establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Additionally, an entity is required to have policies and procedures in place for verifying the above requirements. Condition: During our suspension and debarment testing, CLA noted no suspension and debarment policy in place and no suspension and debarment check was performed over a covered transaction. Questioned costs: $7,442 of known questioned costs. Context: There was only one covered transaction subject to suspension and debarment check that had a contract amount exceeding $25,000 but only $7,442 was paid with federal program. However, no suspension and debarment check was performed. CLA elected to perform a SAM.gov check and noted that vendor (Locke System) is not debarred as of the date of the audit procedure. Cause: Share & Care House and Subsidiary lacks sufficient understanding of the compliance requirements surrounding covered transactions and suspension and debarment check requirements. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding caused Share & Care House and Subsidiary to be noncompliant with program requirements over suspension and debarment. Repeat finding: No. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.
Federal Agency: Department of Housing and Urban Development Federal Program Name: Continuum of Care Assistance Listing Number: 14.267 Federal Award Identification Number and Year: SC-110351 - 2024 SC-111132 - 2024 SC-110353 - 2024 SC-111134 - 2024 SC-110355 - 2024 SC-110349 - 2024 SC-111130 - 2024 Pass-Through Agency: Pierce County Pass-Through Number(s): LP9XHDGASCJ3 Award Period: SC-110351: 7/1/23-6/30/24 SC-111132: 7/1/24-6/30/25 SC-110353: 12/1/23-11/30/24 SC-111134: 12/1/24-11/30/25 SC-110355: 6/1/23-8/31/24 SC-110349: 5/1/23-4/30/24 SC-111130: 5/1/24-4/30/25 Type of finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303(a), recipients of federal funds must "establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award." Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred (2 CFR sections 200.212 and 200.318(h); 2 CFR section 1800.30; 48 CFR section 52.209-6). Additionally, an entity is required to have policies and procedures in place for verifying the above requirements. Condition: During our suspension and debarment testing, CLA noted no suspension and debarment policy in place and no suspension and debarment check was performed over a covered transaction. Questioned costs: $7,442 of known questioned costs. Context: There was only one covered transaction subject to suspension and debarment check that had a contract amount exceeding $25,000 but only $7,442 was paid with federal program. However, no suspension and debarment check was performed. CLA elected to perform a SAM.gov check and noted that vendor (Locke System) is not debarred as of the date of the audit procedure. Cause: Share & Care House and Subsidiary lacks sufficient understanding of the compliance requirements surrounding covered transactions and suspension and debarment check requirements. Effect: Contracts could be entered into with suspended or debarred vendors leading to noncompliance. Improper understanding caused Share & Care House and Subsidiary to be noncompliant with program requirements over suspension and debarment. Repeat finding: No. Recommendation: CLA recommends Share & Care House and Subsidiary to develop and implement a suspension and debarment policy that meets the requirements outlined in Uniform Guidance. CLA also recommends increased training for those individuals involved in procurement and contract approval process to ensure suspension and debarment checks are performed on all covered transactions. Views of responsible officials: Management agrees with the finding and has provided its corrective action plan.
Criteria or Specific Requirement: 2 CFR Part 200 Sections 200.212 and 200.318(h) and per 2 CFR Section 180.300 and 48 CFR Section 52.209-6, organizations must have procedures for verifying that an entity with which hit plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: There was a lack of evidenced to support that a suspension and debarment check was performed prior to entering into a covered transaction. Questioned Costs: None Context: Out of five covered transactions tested, for one vendor, documentation was not retained showing selected entity was checked for suspension and debarment prior to entering into the covered transactions. However, CLA checked the vendor in SAM.gov and noted the vendor is not federally suspended nor debarred. Cause: Inconsistent application of internal policies related to suspension and debarment, and inconsistent retention of supporting documentation. Effect: Inconsistent application of internal suspension and debarment policies could lead to the selection of vendors that are federally suspended and debarred. Repeat Finding: Recommendation: CLA recommends SFP perform suspension and debarment checks prior to entering into the covered transactions paid for with federal funding and to retain documentation evidencing that those checks were performed timely. Increased training may help reinforce the policies and requirements regarding suspension and debarment checks and documentation retention. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria: 2 CFR sections §200.212 and §200.318(h); 48 CFR section §52.209-6 outlines that the non-Federal entity must maintain a procurement policy and verify that agencies in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Center does not have a procurement policy in place nor does it retain the documentation of verification of vendors not suspended or debarred prior to entering into a contract with vendors. Cause: The Center does not have a procurement policy that contains the necessary provisions stated above. Effect: Despite having a written financial purchasing policy, if the Center does not maintain sufficient documentation of procurement evaluations and decisions, the Center's procurement practices will not comply with the Uniform Guidance. Questioned Costs: None Recommendation: The Center should develop a procurement policy in accordance with Uniform Guidance requirements and retain formal documentation with regard to its procurement decisions. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Federal Award Identification Assistance Listing Program Title Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Program Number 21.027 Federal Award ID Number and Year SLFRP1965 Federal Agency U.S. Department of the Treasury Pass-Through Entity Nebraska Department of Health and Human Services Significant Deficiency in Internal Control Over Procurement and Suspension and Debarment Criteria The Health Department’s procurement policy states that documentation of procurements shall be retained for seven years and shall include all federally-required elements of procurement transactions. The Health Department’s procurement policy states that it will require all vendors to self-certify that they are not suspended or debarred. The Health Department is to then check that statement against the Federal System for Award Management. This policy is in compliance with 2 CFR 200.212; 2 CFR 200.318(h); 2 CFR 180.300; 48 CFR 52.209-6. Condition The Health Department did not retain evidence of its procurement of a covered transaction. The Health Department entered into a covered transaction prior to verifying whether the contractor was suspended or debarred. Repeat Finding No. Cause The Health Department did not have a system of controls in place to ensure that their procurement policy was followed. Effect or Potential Effect The Health Department may neglect to procure covered transactions. The Health Department may enter into a covered transaction with a debarred, suspended, or otherwise excluded vendor. Questioned Costs No. Statistical Sample No. Context The Health Department entered into a covered transaction during the year to modernize its restrooms. The Health Department followed its procurement policy and requested proposals from an adequate number of vendors. However, despite repeated attempts to obtain multiple bids, the Health Department was only able to obtain a bid from single vendor. The Health Department proceeded with that bid, as evidenced by the publicly-available board minutes, but failed to follow its procurement policy as it pertains to 1) documentation retention requirements and 2) suspension and debarment. In testing this transaction, the auditor performed a search on the System for Award Management website, noting that the vendor is not on the exclusion list. Recommendation The auditor recommends that the Health Department establish a robust system of controls to ensure it complies with its procurement policy when entering into covered transactions. Views of Responsible Officials See Corrective Action Plan, below.
2024-003 U.S. Department of Treasury, Federal Financial Assistance Listing #21.027, COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.2096 outlines the requirements the non-federal entity verify vendors for which it plans to enter into a covered transaction are not debarred, suspended, or otherwise excluded. Condition: We noted that while the County does have a purchasing policy, elements as required by Uniform Guidance are absent from the policy. In addition, we noted the County did not retain the supporting documentation indicating they had verified vendors they were entering into covered transactions with were neither suspended nor debarred. Cause: The County had not had single audits performed until recently as a result of the increase in funding due to the COVID‐19 pandemic. Because of this, they had not updated their purchasing policy to be in compliance with Uniform Guidance. This also impacted the County’s purchasing and procurement checklist for updating it to including retaining the support the County verified vendors were neither suspended nor debarred in the contract’s procurement file. Effect: While our testing noted no instances of noncompliance, the absence of internal controls over compliance as it relates to having a Uniform Guidance compliant policy, could lead the County to enter into covered transactions that are not compliant with federal regulations. Questioned Costs: None reported. Context/Sampling: Sampling was not used to test the policy. Repeat Finding from Prior Year(s): No Recommendation: The County should review the applicable provisions of the CFR to ensure their written procurement policy is compliant with Uniform Guidance requirements. Additionally, the County should review their checklist and/or document retention requirements for contracts to be sure it includes the support the County verified the vendor was neither suspended nor debarred. Views of Responsible Officials: Management agrees with the finding.
Federal Award Identification Assistance Listing Program Title Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Program Number 21.027 Federal Award ID Number and Year SLFRP1965 Federal Agency U.S. Department of the Treasury Pass-Through Entity Nebraska Department of Health and Human Services Significant Deficiency in Internal Control Over Procurement and Suspension and Debarment Criteria The Health Department’s procurement policy states that documentation of procurements shall be retained for seven years and shall include all federally-required elements of procurement transactions. The Health Department’s procurement policy states that it will require all vendors to self-certify that they are not suspended or debarred. The Health Department is to then check that statement against the Federal System for Award Management. This policy is in compliance with 2 CFR 200.212; 2 CFR 200.318(h); 2 CFR 180.300; 48 CFR 52.209-6. Condition The Health Department did not retain evidence of its procurement of a covered transaction. The Health Department entered into a covered transaction prior to verifying whether the contractor was suspended or debarred. Repeat Finding No. Cause The Health Department did not have a system of controls in place to ensure that their procurement policy was followed. Effect or Potential Effect The Health Department may neglect to procure covered transactions. The Health Department may enter into a covered transaction with a debarred, suspended, or otherwise excluded vendor. Questioned Costs No. Statistical Sample No. Context The Health Department entered into a covered transaction during the year to modernize its restrooms. The Health Department followed its procurement policy and requested proposals from an adequate number of vendors. However, despite repeated attempts to obtain multiple bids, the Health Department was only able to obtain a bid from single vendor. The Health Department proceeded with that bid, as evidenced by the publicly-available board minutes, but failed to follow its procurement policy as it pertains to 1) documentation retention requirements and 2) suspension and debarment. In testing this transaction, the auditor performed a search on the System for Award Management website, noting that the vendor is not on the exclusion list. Recommendation The auditor recommends that the Health Department establish a robust system of controls to ensure it complies with its procurement policy when entering into covered transactions. Views of Responsible Officials See Corrective Action Plan, below.
2024-003 U.S. Department of Treasury, Federal Financial Assistance Listing #21.027, COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.2096 outlines the requirements the non-federal entity verify vendors for which it plans to enter into a covered transaction are not debarred, suspended, or otherwise excluded. Condition: We noted that while the County does have a purchasing policy, elements as required by Uniform Guidance are absent from the policy. In addition, we noted the County did not retain the supporting documentation indicating they had verified vendors they were entering into covered transactions with were neither suspended nor debarred. Cause: The County had not had single audits performed until recently as a result of the increase in funding due to the COVID‐19 pandemic. Because of this, they had not updated their purchasing policy to be in compliance with Uniform Guidance. This also impacted the County’s purchasing and procurement checklist for updating it to including retaining the support the County verified vendors were neither suspended nor debarred in the contract’s procurement file. Effect: While our testing noted no instances of noncompliance, the absence of internal controls over compliance as it relates to having a Uniform Guidance compliant policy, could lead the County to enter into covered transactions that are not compliant with federal regulations. Questioned Costs: None reported. Context/Sampling: Sampling was not used to test the policy. Repeat Finding from Prior Year(s): No Recommendation: The County should review the applicable provisions of the CFR to ensure their written procurement policy is compliant with Uniform Guidance requirements. Additionally, the County should review their checklist and/or document retention requirements for contracts to be sure it includes the support the County verified the vendor was neither suspended nor debarred. Views of Responsible Officials: Management agrees with the finding.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.
Control Deficiencies Suspension and Debarment – Child Nutrition Cluster Type of Finding: Significant deficiency in internal control compliance Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Pass-Through Number(s): 2024-056328-DPI-SB-546, 2024-056328-DPI-NSL-547, 2024-056328-DPI-SFSP-586 Award Period: 7/1/23 – 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The organization should have procedures for verifying that an entity with which it plans to enter a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: The District has a policy in place that meets the requirements of Uniform Guidance, however, the policy was not followed in 2023-2024. Questioned Costs: None noted. Context: For 5 out of 5 vendors tested, the District did not have documentation of checking for suspension and debarment. Cause: Due to turnover in the Food Service Director Position and related support staff, new Food Service Director was not able to produce documentation that suspension and debarment was checked for the vendors tested. Effect: The district could potentially be using Federal Grant dollars for suspended or debarred vendors Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District implement a process to check for suspension and debarment for all vendors exceeding the threshold for purchases. Views of responsible officials: There is no disagreement with the finding
Control Deficiencies Suspension and Debarment – Child Nutrition Cluster Type of Finding: Significant deficiency in internal control compliance Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Pass-Through Number(s): 2024-056328-DPI-SB-546, 2024-056328-DPI-NSL-547, 2024-056328-DPI-SFSP-586 Award Period: 7/1/23 – 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The organization should have procedures for verifying that an entity with which it plans to enter a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: The District has a policy in place that meets the requirements of Uniform Guidance, however, the policy was not followed in 2023-2024. Questioned Costs: None noted. Context: For 5 out of 5 vendors tested, the District did not have documentation of checking for suspension and debarment. Cause: Due to turnover in the Food Service Director Position and related support staff, new Food Service Director was not able to produce documentation that suspension and debarment was checked for the vendors tested. Effect: The district could potentially be using Federal Grant dollars for suspended or debarred vendors Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District implement a process to check for suspension and debarment for all vendors exceeding the threshold for purchases. Views of responsible officials: There is no disagreement with the finding
Control Deficiencies Suspension and Debarment – Child Nutrition Cluster Type of Finding: Significant deficiency in internal control compliance Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Pass-Through Number(s): 2024-056328-DPI-SB-546, 2024-056328-DPI-NSL-547, 2024-056328-DPI-SFSP-586 Award Period: 7/1/23 – 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The organization should have procedures for verifying that an entity with which it plans to enter a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: The District has a policy in place that meets the requirements of Uniform Guidance, however, the policy was not followed in 2023-2024. Questioned Costs: None noted. Context: For 5 out of 5 vendors tested, the District did not have documentation of checking for suspension and debarment. Cause: Due to turnover in the Food Service Director Position and related support staff, new Food Service Director was not able to produce documentation that suspension and debarment was checked for the vendors tested. Effect: The district could potentially be using Federal Grant dollars for suspended or debarred vendors Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District implement a process to check for suspension and debarment for all vendors exceeding the threshold for purchases. Views of responsible officials: There is no disagreement with the finding
Control Deficiencies Suspension and Debarment – Child Nutrition Cluster Type of Finding: Significant deficiency in internal control compliance Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Pass-Through Number(s): 2024-056328-DPI-SB-546, 2024-056328-DPI-NSL-547, 2024-056328-DPI-SFSP-586 Award Period: 7/1/23 – 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The organization should have procedures for verifying that an entity with which it plans to enter a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: The District has a policy in place that meets the requirements of Uniform Guidance, however, the policy was not followed in 2023-2024. Questioned Costs: None noted. Context: For 5 out of 5 vendors tested, the District did not have documentation of checking for suspension and debarment. Cause: Due to turnover in the Food Service Director Position and related support staff, new Food Service Director was not able to produce documentation that suspension and debarment was checked for the vendors tested. Effect: The district could potentially be using Federal Grant dollars for suspended or debarred vendors Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District implement a process to check for suspension and debarment for all vendors exceeding the threshold for purchases. Views of responsible officials: There is no disagreement with the finding
Control Deficiencies Suspension and Debarment – Child Nutrition Cluster Type of Finding: Significant deficiency in internal control compliance Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Pass-Through Agency: Wisconsin Department of Instruction Pass-Through Number(s): 2024-056328-DPI-SB-546, 2024-056328-DPI-NSL-547, 2024-056328-DPI-SFSP-586 Award Period: 7/1/23 – 6/30/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The organization should have procedures for verifying that an entity with which it plans to enter a covered transaction is not debarred, suspended, or otherwise excluded (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6) Condition: The District has a policy in place that meets the requirements of Uniform Guidance, however, the policy was not followed in 2023-2024. Questioned Costs: None noted. Context: For 5 out of 5 vendors tested, the District did not have documentation of checking for suspension and debarment. Cause: Due to turnover in the Food Service Director Position and related support staff, new Food Service Director was not able to produce documentation that suspension and debarment was checked for the vendors tested. Effect: The district could potentially be using Federal Grant dollars for suspended or debarred vendors Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District implement a process to check for suspension and debarment for all vendors exceeding the threshold for purchases. Views of responsible officials: There is no disagreement with the finding
Suspension and Debarment Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Health Center Infrastructure Support Assistance Listing Number: 93.526 Federal Award Identification Number: C8ECS44866-01-00 Award Periods: September 15, 2021 – September 14, 2024 Type of Finding: Immaterial noncompliance and significant deficiency in internal control over compliance Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Organization did not check to see if a vendor was suspended or debarred prior to entering a contract with the vendor. Questioned Costs: $38,515. Context: The Organization purchased medical equipment from a vendor without first verifying the vendor was not suspended or debarred. Cause: Oversight Effect: Formalized procedures should be in place to ensure the Organization does not engage with a vendor that is debarred, suspended, or otherwise excluded. Repeat Finding: No. Recommendation: CLA recommends the Organization update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded. Views of Responsible Officials: There is no disagreement with the audit finding.
2024-002 – Suspension and Debarment Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL1780L5T172100 - 2022 IL0315LST142215 - 2023 IL1651L5T142103 - 2022 Award Periods: August 1, 2022 – July 31, 2023; August 1, 2023 – July 31, 2024; July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Agency did not retain the documentation of verification of vendors not suspended or debarred prior to entering into a contract with the vendor. Questioned Costs: None Context: The Agency procured grant writing services and made rental assistance payments to the vendors without maintaining the documentation of verification for the vendors not being suspended or debarred. Cause: Unknown Effect: Formalized procedures should be in place to ensure the Agency does not engage with vendors that are debarred, suspended, or otherwise excluded. Repeat Finding: This finding is not a repeat finding. Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Views of Responsible Officials: There is no disagreement with this audit finding.
Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-003 – Procurement and Suspension and Debarment — Material Weakness Department of Health and Human Services Research and Development Cluster Department of Health and Human Services, National Institutes of Health, Assistance Listing No. 93.859 (Biomedical Research and Research Training) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure vendors are not suspended or debarred. In accordance with 2 CFR 200.212 and 200.318(h)), when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year (or any amount in the case of a subrecipient). Condition: The University’s controls were not operating effectively to reasonably ensure the University verified the vendor was not suspended or debarred from participation in federal programs/grants prior to entering into a contract with the vendor. The University’s procurement policy requires vendor transactions equal to or greater than $25,000 undergo verification to ensure the vendor is not suspended or debarred, prior to entering into a contract with the vendor. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The University did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: $0 Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the University had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-002 Type of Finding: Significant deficiency in internal controls over compliance and immaterial non- compliance Criteria: In accordance with the Uniform Guidance (2 CFR 200.512), it is the responsibility of Connected Lane County’s management to ensure there are properly designed and implemented internal controls in order to timely complete the Organization’s annual audit and submit it to the federal audit clearinghouse. Condition and Context: The audit for the year ended June 30, 2023 was not able to be completed within nine months of the fiscal year end as required due to required corrections to the accounting records and delays in providing information required to complete the audit. The audit was submitted more than nine months after the end of the audit period. Cause of Condition: The audit for the year ended June 30, 2023 was not able to be completed within nine months of the fiscal year end as required due to required corrections to the accounting records and delays in providing information required to complete the audit. Effect of Condition: The effect of the condition is that the Organization did not comply with the provisions in 2 CFR 200.212. This is considered immaterial non-compliance. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend management and the Board work closely with the Finance Manager to remedy the internal control over financial reporting deficiency and also to find efficiencies in the accounting systems to allow for timely close of the Organization’s financial records in order to allow for the audit to be completed timely. Additionally, we recommend the Organization review its document retention and storage policies to ensure documentation is well organized and easy to locate when requested for the audit.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.
2024-003: Suspension and Debarment—Material Weakness U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. Also, the Uniform Guidance (2 CFR 200.212 and 200.318(h)) stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when expending $25,000 or more in a year. Condition: The District did not have controls in place to reasonably ensure any entity receiving more than $25,000 in federal grant funds was not suspended or debarred, prior to providing them with federal funds. Cause: A lack of controls to reasonably ensure this verification was performed. Effect or potential effect: The District did not have controls in place to reasonably ensure compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: For all sample selections tested in the major program, documentation was not maintained that could provide evidence that the District had performed the required verification. None of the samples tested were identified as suspended or debarred entities. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the District develop proper controls and procedures to determine whether vendors have been suspended or debarred prior to entering into contracts or purchase orders for all transactions, and maintain documentation supporting this verification. View of responsible officials: Management agrees with this finding.