Reporting a determination that an applicant is not qualified for a Federal award.
Finding #24-004 – Suspension & Debarment Program Names: 3rd Street Housing Project Eagle Community Pool Replacement CFDA Titles and Numbers: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: United States Treasury Pass-through Agency: Colorado Department of Local Affairs Award Year: December 31, 2024 Condition: The Town of Eagle, Colorado, does not have policies and procedures in place to ensure that they do not contract with or make awards to parties that are suspended or debarred, resulting in a lack of compliance with Federal procurement. Criteria or Specific Requirement: The Town of Eagle, Colorado, must comply with procurement, suspension & debarment standards set out at 2 CFR section 200.303 et al. within Uniform Guidance. Per 2CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts within certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Questioned Costs: N/A Context: Although the Town of Eagle, Colorado, does not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify any instances where Federal grant awards were paid to suspended or debarred vendors for 16 of 16 suspension and debarment transactions selected for testing. Cause: Management was not aware of the requirements for determining suspension and debarment status under 2CFR section 180 within Uniform Guidance. Effect: The Town of Eagle, Colorado, is at risk for noncompliance with Federal grants as it relates to suspension and debarment. Recommendation: We recommend that the Town of Eagle, Colorado, implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services.
Finding #24-002 – Significant Deficiency in Internal Control over Financial Reporting: Suspension & Debarment Program Names: 3rd Street Housing Project Eagle Community Pool Replacement CFDA Titles and Numbers: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: United States Treasury Pass-through Agency: Colorado Department of Local Affairs Award Year: December 31, 2024 Condition: The Town of Eagle, Colorado, does not have policies and procedures in place to ensure that they do not contract with or make awards to parties that are suspended or debarred, resulting in a lack of internal controls over Federal procurement. Criteria or Specific Requirement: The Town of Eagle, Colorado, must comply with procurement, suspension & debarment standards set out at 2 CFR section 200.303 et al. within Uniform Guidance. Per 2CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts within certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Questioned Costs: N/A Context: Although the Town of Eagle, Colorado, does not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify any instances where Federal grant awards were paid to suspended or debarred vendors for 16 of 16 suspension and debarment transactions selected for testing. Cause: Management was not aware of the requirements for determining suspension and debarment status under 2CFR section 180 within Uniform Guidance. Effect: The Town of Eagle, Colorado, is at risk for noncompliance with Federal grants as it relates to suspension and debarment. Recommendation: We recommend that the Town of Eagle, Colorado, implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services. Finding #24-002 – Significant Deficiency in Internal Control over Financial Reporting: Suspension & Debarment Program Names: 3rd Street Housing Project Program Names: 3rd Street Housing Project Eagle Community Pool Replacement CFDA Titles and Numbers: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: United States Treasury Pass-through Agency: Colorado Department of Local Affairs Award Year: December 31, 2024 Condition: The Town of Eagle, Colorado, does not have policies and procedures in place to ensure that they do not contract with or make awards to parties that are suspended or debarred, resulting in a lack of internal controls over Federal procurement. Criteria or Specific Requirement: The Town of Eagle, Colorado, must comply with procurement, suspension & debarment standards set out at 2 CFR section 200.303 et al. within Uniform Guidance. Per 2CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts within certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Questioned Costs: N/A Context: Although the Town of Eagle, Colorado, does not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify any instances where Federal grant awards were paid to suspended or debarred vendors for 16 of 16 suspension and debarment transactions selected for testing. Cause: Management was not aware of the requirements for determining suspension and debarment status under 2CFR section 180 within Uniform Guidance. Effect: The Town of Eagle, Colorado, is at risk for noncompliance with Federal grants as it relates to suspension and debarment. Recommendation: We recommend that the Town of Eagle, Colorado, implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services.
Finding #24-004 – Suspension & Debarment Program Names: 3rd Street Housing Project Eagle Community Pool Replacement CFDA Titles and Numbers: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: United States Treasury Pass-through Agency: Colorado Department of Local Affairs Award Year: December 31, 2024 Condition: The Town of Eagle, Colorado, does not have policies and procedures in place to ensure that they do not contract with or make awards to parties that are suspended or debarred, resulting in a lack of compliance with Federal procurement. Criteria or Specific Requirement: The Town of Eagle, Colorado, must comply with procurement, suspension & debarment standards set out at 2 CFR section 200.303 et al. within Uniform Guidance. Per 2CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts within certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Questioned Costs: N/A Context: Although the Town of Eagle, Colorado, does not have policies or procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred, we did not identify any instances where Federal grant awards were paid to suspended or debarred vendors for 16 of 16 suspension and debarment transactions selected for testing. Cause: Management was not aware of the requirements for determining suspension and debarment status under 2CFR section 180 within Uniform Guidance. Effect: The Town of Eagle, Colorado, is at risk for noncompliance with Federal grants as it relates to suspension and debarment. Recommendation: We recommend that the Town of Eagle, Colorado, implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and will implement policies and procedures to ensure that potential vendors are not suspended or debarred prior to contracting with them for goods and services.
Assistance Number: 16.753 Congressionally Recommended Awards (CRA) Year: 2024 Name of Federal Agency: U.S. Department of Justice Name of Pass-Thru Agency: Direct award Type of Compliance Finding: I – Procurement and Suspension and Debarment Condition: During our testing, we noted that the City did not perform or document required suspension and debarment checks for certain vendors and contractors paid with federal funds. The City did not obtain or retain evidence, such as a certification from the vendor or a verification from the System for Award Management (SAM), to ensure that vendors were not suspended, debarred, or otherwise excluded from federal programs. Criteria: The Uniform Guidance (2 CFR §200.213) requires non-federal entities to ensure that federal funds are not awarded to or expended with parties that are suspended, debarred, or otherwise excluded. This requirement can be satisfied by obtaining a vendor certification or by checking the SAM.gov system prior to entering into a covered transaction. Questioned Costs: N/A Context: The City did not document the suspension and debarment check on one of the five transactions tested. The sample size was determined based upon guidelines provided by the AICPA which is not a statistically valid sample. Cause: The City did not have adequate procedures in place to ensure that suspension and debarment checks were consistently performed and documented. Effect: Without performing suspension and debarment checks, the City risks expending federal funds on ineligible vendors, which could result in questioned costs and potential repayment of federal funds. Recommendation: We recommend that the City implement procedures to ensure suspension and debarment checks are performed for all covered transactions and that evidence of such checks is retained in the procurement files. Views of Responsible Officials (Unaudited): The City is in agreement with the finding and appreciates the auditor’s recommendations for improvements. While federal contract compliance language is included in agreements that are being paid with federal funds, this case occurred because the original contract (2020) predated knowledge that federal funds would later be applied (2022). The oversight highlights the need for additional training and coordination to ensure procurement and legal staff are notified whenever federal funding is applied to an existing contract or amendment.
Assistance Number: 93.493 Mobile Integrated Health Year: 2024 Name of Federal Agency: U.S. Department of Health and Human Services Name of Pass-Thru Agency: Direct award Type of Compliance Finding: I – Procurement and Suspension and Debarment Condition: During our testing, we noted that the City did not perform or document required suspension and debarment checks for certain vendors and contractors paid with federal funds. The City did not obtain or retain evidence, such as a certification from the vendor or a verification from the System for Award Management (SAM), to ensure that vendors were not suspended, debarred, or otherwise excluded from federal programs. Criteria: The Uniform Guidance (2 CFR §200.213) requires non-federal entities to ensure that federal funds are not awarded to or expended with parties that are suspended, debarred, or otherwise excluded. This requirement can be satisfied by obtaining a vendor certification or by checking the SAM.gov system prior to entering into a covered transaction. Questioned Costs: N/A Context: The City did not document the suspension and debarment check on one of four transactions tested. The sample size was determined based upon guidelines provided by the AICPA which is not a statistically valid sample. Cause: The City did not have adequate procedures in place to ensure that suspension and debarment checks were consistently performed and documented. Effect: Without performing suspension and debarment checks, the City risks expending federal funds on ineligible vendors, which could result in questioned costs and potential repayment of federal funds. Recommendation: We recommend that the City implement procedures to ensure suspension and debarment checks are performed for all covered transactions and that evidence of such checks is retained in the procurement files. Views of Responsible Officials (Unaudited): The City is in agreement with the finding and appreciates the auditor’s recommendations for improvements. While the City does have standard procedures in place to prevent this issue from happening, this payment was made under a competition exception process that did not provide the procurement or legal team an opportunity to ensure compliance with the Uniform Guidance. This issue highlighted a need for stronger training and enhanced internal controls to capture nontraditional purchases funded with federal dollars and ensure that all purchases with federal funds follow a competitive procurement process.
Compliance Requirement Procurement Type of Finding Material Weakness in Internal Control over Compliance, Material Noncompliance Program Port Security Grant Program ALN# 97.056 Federal Agency Department of Homeland Security – Direct Award Federal Award Year 2020, 2021, 2022 and 2023 Grant Number EMW-2020-PU-00079 – IJ#1, IJ#3, IJ #4 EMW-2021-PU-00030 – IJ#1, IJ#3 EMW-2022-PU-00022 – IJ#1, IJ#2, EMW-2023-PU-00164 – IJ#1, IJ#2, IJ#3, IJ#4 EMW-2024-PU-05541 – IJ#4 Questioned Costs $463,460 Criteria - Federal rules require grant recipients to follow strict purchasing standards. This includes seeking fair and open competition when buying goods or services, obtaining bids or quotes once purchases reach certain dollar thresholds, and verifying that vendors are not suspended or barred from receiving federal funds through the SAM.gov system. Federal rules set strict procurement standards that the District must follow: • 2 CFR 200.318 – Requires non-federal entities to maintain oversight to ensure contractors perform in accordance with the terms, conditions, and specifications of their contracts. • 2 CFR 200.319 – Requires full and open competition in all procurement transactions. • 2 CFR 200.320 – Establishes methods of procurement, including micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive proposals. • 2 CFR 200.323 – Requires cost or price analysis for procurements above the Simplified Acquisition Threshold. • 2 CFR 200.213 – Requires checks for suspension and debarment (SAM.gov).Under Louisiana law, political subdivisions such as ports are also subject to state purchasing thresholds: (a) $0 – $9,999: Purchases may be made directly but must be reasonable and properly documented. (b) $10,000 – $60,000: At least three (3) telephone or written quotations are required, with documentation kept on file. (c) Over $60,000: A formal advertised public bid process is required in compliance with Louisiana Public Bid Law. For professional services, the District is required to follow competitive selection processes consistent with their policies, Louisiana state law and federal guidance, ensuring fair opportunity, transparency, and reasonable pricing. Condition - The District failed to comply with federal procurement standards in multiple areas, indicating a pervasive breakdown in procurement controls and noncompliance with 2 CFR 200.318–.327. a) The District did not obtain competitive bids for the camera purchases and installation, resulting in questioned costs of $234,217 b) For professional services contracts funded by the PSGP, relating the IT services, engineering and consulting services, and GIS implantation services, the District did not maintain records documenting requests for price quotes or maintain records demonstrating the reasonableness of costs. Resulting in questioned costs of $305,657. c) For all ten (10) vendors tested under the Port Security Grant Program, the District did not retain documentation demonstrating that SAM.gov suspension and debarment verifications were performed prior to award or payment. Cause - The District failed to enforce federally required procurement standards and did not maintain sufficient documentation to demonstrate compliance. This deficiency reflects a significant weakness in procurement oversight and a lack of management attention to ensuring adherence with federal regulations governing competition, cost reasonableness, and vendor selection. Effect - Because the District did not obtain the required bids, quotes, or suspension and debarment checks, it cannot demonstrate compliance with federal procurement standards. This failure increases the risk of waste, favoritism, or contracting with ineligible vendors, and resulted in questioned costs as calculated by the auditor.Recommendation - The District must consistently apply written procurement policies that require competitive bids or price quotes for all purchases and professional services. Documentation of price reasonableness must be retained for every procurement action to ensure compliance with 2 CFR 200.318–.327 The District must document SAM.gov suspension and debarment verification for all vendors and contractors prior to contract execution or payment. This documentation must be maintained in the procurement file. The District must consult with FEMA regarding the allowability of identified questioned costs.
Criteria or specific requirement: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Township could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for all of the vendors tested were not documented on the 40 transactions tested. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: The Township relied on State policies and procedures for suspension and debarment for State piggyback contracts, rather than applying their own established controls to these contracts Effect: The Township is not in compliance with federal suspension and debarment regulations. Repeat Finding: No. Recommendation: The Township should ensure that established policies and procedures related to suspension and debarment are applied to all contracts, even for piggyback agreements adopted from the State. Views of Responsible Officials and Planned Corrective Action: The Township has created a procedure to regularly check Sam.gov for suspension and debarment prior to issuing purchases orders or contracts and have it reviewed.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Criteria or Specific Requirement: Per 2 CFR §200.318 - §200.326, non-federal entities must follow procurement procedures that ensure full and open competition and maintain proper documentation of procurement transactions. Additionally, under 2 CFR §200.213, entities must verify that vendors and subrecipients are not suspended or debarred before entering into contracts funded by federal awards. Condition: AIRA did not retain sufficient/updated documentation to support compliance with Uniform Guidance procurement standards. Specifically: • Procurement files lacked evidence of cost/price analysis and vendor selection criteria for purchases exceeding the micro-purchase threshold of $10,000. • The entity did not retain verification records confirming that selected vendors were not suspended or debarred in SAM.gov before contract execution. Cause: The deficiency appear to result from inadequate internal controls over procurement documentation and a lack of formalized procedures ensuring compliance with federal procurement and debarment requirements. Effect or Potential Effect: Failure to maintain proper procurement documentation and verify vendor eligibility increases the risk of noncompliance with federal requirements. This may lead to questioned costs and potential disallowance of federal expenditures. Questioned Costs: Not applicable as there were no questioned costs related to noncompliance. Recommendation: We recommend AIRA strengthen its internal controls over procurement documentation by considering the following: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. A procurement checklist includes key compliance steps such as: a. Documentation of competitive procurement such as bids, proposals, or price comparisons. b. Justification for vendor selection, including cost/price analysis. c. Approval signatures from designated officials. d. Verification of vendor eligibility through SAM.gov before contract execution. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. The entity should implement a procurement control process where a designated staff member completes the following steps: a. Searches SAM.gov for each vendor before contract execution. b. Prints and retains a copy of the vendor’s eligibility verification. c. Signs and dates a verification form certifying the check was performed. d. Includes this form in the procurement file. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. The training should cover: a. Procurement methods (small purchase, micro-purchase, simplified acquisitions, competitive proposals, sealed bids, sole source) competitive proposals, sealed bids) b. Documentation requirements under 2 CFR Part 200. c. Vendor debarment checks and maintaining verification records. d. Retention requirements for procurement documents. Repeat finding from prior year: No Views of Responsible Officials: Management agrees with the finding. See attached corrective action plan.
Criteria or Specific Requirement: Per 2 CFR §200.318 - §200.326, non-federal entities must follow procurement procedures that ensure full and open competition and maintain proper documentation of procurement transactions. Additionally, under 2 CFR §200.213, entities must verify that vendors and subrecipients are not suspended or debarred before entering into contracts funded by federal awards. Condition: AIRA did not retain sufficient/updated documentation to support compliance with Uniform Guidance procurement standards. Specifically: • Procurement files lacked evidence of cost/price analysis and vendor selection criteria for purchases exceeding the micro-purchase threshold of $10,000. • The entity did not retain verification records confirming that selected vendors were not suspended or debarred in SAM.gov before contract execution. Cause: The deficiency appear to result from inadequate internal controls over procurement documentation and a lack of formalized procedures ensuring compliance with federal procurement and debarment requirements. Effect or Potential Effect: Failure to maintain proper procurement documentation and verify vendor eligibility increases the risk of noncompliance with federal requirements. This may lead to questioned costs and potential disallowance of federal expenditures. Questioned Costs: Not applicable as there were no questioned costs related to noncompliance. Recommendation: We recommend AIRA strengthen its internal controls over procurement documentation by considering the following: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. A procurement checklist includes key compliance steps such as: a. Documentation of competitive procurement such as bids, proposals, or price comparisons. b. Justification for vendor selection, including cost/price analysis. c. Approval signatures from designated officials. d. Verification of vendor eligibility through SAM.gov before contract execution. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. The entity should implement a procurement control process where a designated staff member completes the following steps: a. Searches SAM.gov for each vendor before contract execution. b. Prints and retains a copy of the vendor’s eligibility verification. c. Signs and dates a verification form certifying the check was performed. d. Includes this form in the procurement file. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. The training should cover: a. Procurement methods (small purchase, micro-purchase, simplified acquisitions, competitive proposals, sealed bids, sole source) competitive proposals, sealed bids) b. Documentation requirements under 2 CFR Part 200. c. Vendor debarment checks and maintaining verification records. d. Retention requirements for procurement documents. Repeat finding from prior year: No Views of Responsible Officials: Management agrees with the finding. See attached corrective action plan.
Criteria or Specific Requirement: Per 2 CFR §200.318 - §200.326, non-federal entities must follow procurement procedures that ensure full and open competition and maintain proper documentation of procurement transactions. Additionally, under 2 CFR §200.213, entities must verify that vendors and subrecipients are not suspended or debarred before entering into contracts funded by federal awards. Condition: AIRA did not retain sufficient/updated documentation to support compliance with Uniform Guidance procurement standards. Specifically: • Procurement files lacked evidence of cost/price analysis and vendor selection criteria for purchases exceeding the micro-purchase threshold of $10,000. • The entity did not retain verification records confirming that selected vendors were not suspended or debarred in SAM.gov before contract execution. Cause: The deficiency appear to result from inadequate internal controls over procurement documentation and a lack of formalized procedures ensuring compliance with federal procurement and debarment requirements. Effect or Potential Effect: Failure to maintain proper procurement documentation and verify vendor eligibility increases the risk of noncompliance with federal requirements. This may lead to questioned costs and potential disallowance of federal expenditures. Questioned Costs: Not applicable as there were no questioned costs related to noncompliance. Recommendation: We recommend AIRA strengthen its internal controls over procurement documentation by considering the following: 1. Implementing a standardized procurement checklist to ensure all required documentation is maintained. A procurement checklist includes key compliance steps such as: a. Documentation of competitive procurement such as bids, proposals, or price comparisons. b. Justification for vendor selection, including cost/price analysis. c. Approval signatures from designated officials. d. Verification of vendor eligibility through SAM.gov before contract execution. 2. Establishing a formal review process to verify and document vendor eligibility through SAM.gov before awarding federally funded contracts. The entity should implement a procurement control process where a designated staff member completes the following steps: a. Searches SAM.gov for each vendor before contract execution. b. Prints and retains a copy of the vendor’s eligibility verification. c. Signs and dates a verification form certifying the check was performed. d. Includes this form in the procurement file. 3. Conducting regular training for staff involved in procurement to reinforce federal compliance requirements. The training should cover: a. Procurement methods (small purchase, micro-purchase, simplified acquisitions, competitive proposals, sealed bids, sole source) competitive proposals, sealed bids) b. Documentation requirements under 2 CFR Part 200. c. Vendor debarment checks and maintaining verification records. d. Retention requirements for procurement documents. Repeat finding from prior year: No Views of Responsible Officials: Management agrees with the finding. See attached corrective action plan.
Finding 2024-004 Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the Federal awards for which documentation of SAM Exclusion checks were unavailable for our inspection. Cause: Administrative oversight. Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: $102,541 Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in nature. Identification as a Repeat Finding: N/A Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings are run on all contractual relationships that are charged to the Federal awards, and that documentation of such screenings are maintained in the vendor files.
Finding 2024-004 Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the Federal awards for which documentation of SAM Exclusion checks were unavailable for our inspection. Cause: Administrative oversight. Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: $102,541 Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in nature. Identification as a Repeat Finding: N/A Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings are run on all contractual relationships that are charged to the Federal awards, and that documentation of such screenings are maintained in the vendor files.
Finding 2024-004 Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the Federal awards for which documentation of SAM Exclusion checks were unavailable for our inspection. Cause: Administrative oversight. Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: $102,541 Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in nature. Identification as a Repeat Finding: N/A Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings are run on all contractual relationships that are charged to the Federal awards, and that documentation of such screenings are maintained in the vendor files.
Finding 2024-004 Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the Federal awards for which documentation of SAM Exclusion checks were unavailable for our inspection. Cause: Administrative oversight. Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: $102,541 Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in nature. Identification as a Repeat Finding: N/A Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings are run on all contractual relationships that are charged to the Federal awards, and that documentation of such screenings are maintained in the vendor files.
Finding 2024-004 Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the Federal awards for which documentation of SAM Exclusion checks were unavailable for our inspection. Cause: Administrative oversight. Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: $102,541 Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in nature. Identification as a Repeat Finding: N/A Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings are run on all contractual relationships that are charged to the Federal awards, and that documentation of such screenings are maintained in the vendor files.
Finding 2024-004 Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the Federal awards for which documentation of SAM Exclusion checks were unavailable for our inspection. Cause: Administrative oversight. Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: $102,541 Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in nature. Identification as a Repeat Finding: N/A Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings are run on all contractual relationships that are charged to the Federal awards, and that documentation of such screenings are maintained in the vendor files.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
Finding 2024-003 Procurement, Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Assistance Listing #15.657 Criteria or Specific Requirement: § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non- Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person.Condition: During our audit, we noted contractual relationships under the Federal awards for which evidence of procurement procedures and documentation of SAM Exclusion checks were unavailable for our inspection. It is our understanding that some contracts were procured under noncompetitive (sole source) justification. However, in certain instances we were unable to review documentation detailing the history and rationale of the procurements. Cause: The Organization's processes in place during 2024 did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Additionally, the Organization does not have a formal policy in place related to contractor screenings under CFR §200.213. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Additionally, the Organization may have inadvertently selected noncompetitive proposals method when the circumstances did not meet the requirements noted in § 200.320 (f) Methods of procurement to be followed, and thereby failing to administer full and open competition as required by the regulations. Finally, the Organization could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A Context: The Organization failed to adhere to its procurement policy, and hence, noncompliance with Federal standards. Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: Yes, continuation of Finding 2023-003 Recommendation: We then recommend that the Organization ensure its policy is distributed and communicated in a formal manner to its employees, and that management properly enforce compliance with its policy. All procurement actions should be clearly documented in writing and maintained in the vendor or contractor files. We also recommend that the Organization enhance its existing policy related to noncompetitive procurement to ensure include the five specific circumstances in which noncompetitive procurement can be used under CFR 200.320. Additionally, we recommend that the Organization enhance its policies to include screening procedures related to 200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award.
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
2024-009– Significant Deficiency in Internal Control Over Procurement Criteria: Per OMB 2 CFR 200.213, a pass-through entity must verify that the subrecipient is not excluded or disqualified from receiving or participating in Federal Awards. Further, per Harris County’s Procedure for Executive Order 12549 Debarment and Suspension, prior to award in Commissioners Court, the Harris County Purchasing Office will determine if a vendor has been debarred or suspended by the Federal Government. Condition: During our testing, D&T identified Harris County could not provide evidence indicating that 2 of the 3 vendors selected for testing were properly checked against the excluded parties list before entering into a contract with the vendor. It was determined that the entities were neither suspended nor debarred as of the testing date. Cause: The County failed to search all vendors for suspension and debarment and maintain evidence of the search within the bid package. Effect: Grant funded contracts could be awarded to vendors that are suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Context: We were not able to receive evidence for 2 of 3 vendor selections to support Harris County verified the vendors were not suspended/debarred before entering into contracts with the vendors. Recommendation: Harris County should implement policies in alignment with the OMB 2 CFR 200.213 (Suspension and debarment) to ensure that all vendors used in federal award programs are not suspended or debarred and that documentation of this procedure is maintained in the vendor files prior to entering into a contract and expending funds. Views of Responsible Officials: See Corrective Action Plan County Contact Person(s): Paige McInnis, Purchasing Agent Tiffany Harris, Compliance Manager
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.
Suspension and Debarment (Material Weakness in Internal Control Over Compliance) Criteria – The Uniform Guidance prohibits non-federal entities from contracting with parties through covered transactions that are suspended or debarred. “Covered transactions” include those procurement contracts for good and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to be equal to or exceed $25,000 or meet certain other specified criteria (2 CFR 200.213 and 2 CFR part 180). Condition and Context – We reviewed covered transactions in excess of $25,000 that were subject to suspension and debarment requirements, as noted below, for evidence of review of the Federal Excluded Parties List System or other controls to ensure that the vendors were not suspended or debarred before the Heath Board entered into contracts with those vendors. Control deficiencies were identified in the suspension and debarment process, include the following for these programs: • Assistance Listing Number 93.193 – The program had 24 covered transactions over $25,000. From this full population, we randomly selected a sample of nine (9) covered transactions subject to suspension and debarment requirements. For three (3) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. • Assistance Listing Number 93.231 – The program had four covered transactions over $25,000. We tested all four covered transactions subject to suspension and debarment requirements. For one (1) of the items tested the Health Board could not provide the required evidence that the Health Board performed its own suspension and debarment search. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Health Board’s established policies to maintain documentation to support requirements under Uniform Guidance. Effect – The Health Board could be at risk of contracting with vendors that have been suspended or debarred from governmental contracts. Questioned Costs – There were no questioned costs associated with this finding. Repeat Finding – This is not a repeat finding. Recommendation – The Health Board has adequate policies in place, so we recommend that all programs and department overseeing all programs receive updated training on the Health Board’s procurement requirements. Views of responsible officials – Management agrees with the auditors' findings and will implement the corrective action plan to address the issue identified.