Reporting a determination that an applicant is not qualified for a Federal award.
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: 2024-006 Procurement Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): §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 that while DOL has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for competitive and noncompetitive selections in our sample. Additionally, DOL lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: DOL’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. 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. Finally, DOL 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: 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: N/A Recommendation: We then recommend that DOL develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Significant Deficiencies 2024-004 Child Nutrition Cluster – Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Child Nutrition program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performed required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the school lunch fund and therefore represented purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review the requirements of 2 CFR Section 200.213 and ensure that the procurement procedures are being followed and perform a review of the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds to the vendor. This was identified as part of the Administrative Review conducted in November 2023 by the NYS Education Department (Child Nutrition Program). The District has already started the process of working on corrective action.
Significant Deficiencies 2024-004 Child Nutrition Cluster – Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Child Nutrition program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performed required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the school lunch fund and therefore represented purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review the requirements of 2 CFR Section 200.213 and ensure that the procurement procedures are being followed and perform a review of the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds to the vendor. This was identified as part of the Administrative Review conducted in November 2023 by the NYS Education Department (Child Nutrition Program). The District has already started the process of working on corrective action.
Significant Deficiencies 2024-004 Child Nutrition Cluster – Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Child Nutrition program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performed required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the school lunch fund and therefore represented purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review the requirements of 2 CFR Section 200.213 and ensure that the procurement procedures are being followed and perform a review of the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds to the vendor. This was identified as part of the Administrative Review conducted in November 2023 by the NYS Education Department (Child Nutrition Program). The District has already started the process of working on corrective action.
Significant Deficiencies 2024-004 Child Nutrition Cluster – Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Child Nutrition program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performed required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the school lunch fund and therefore represented purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: The District will review the requirements of 2 CFR Section 200.213 and ensure that the procurement procedures are being followed and perform a review of the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds to the vendor. This was identified as part of the Administrative Review conducted in November 2023 by the NYS Education Department (Child Nutrition Program). The District has already started the process of working on corrective action.
Special Education Cluster – Procurement Information on Federal Program: U.S. Department of Education Special Education Cluster (Special Education – Grants to State (IDEA, Part B) and Special Education – Preschool Grants (IDEA Preschool) Assistance Listing numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Special Education program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performed required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the special education cluster and therefore represents purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: As of November 1, 2024, the District will have implemented a process to determine the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds.
Special Education Cluster – Procurement Information on Federal Program: U.S. Department of Education Special Education Cluster (Special Education – Grants to State (IDEA, Part B) and Special Education – Preschool Grants (IDEA Preschool) Assistance Listing numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Special Education program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performed required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the special education cluster and therefore represents purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Views of the Responsible Officials and Planned Corrective Actions: As of November 1, 2024, the District will have implemented a process to determine the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of the District’s vendors charged to the fund, and none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: The Bethlehem Central School District appreciates the requirements of 2 CFR Section 200.213. The District's recent review of vendors indicated that there weren't any instances of ineligibility for participation in Federal assistance programs. To ensure formalized compliance, the District is updating procurement procedures which will highlight that the Purchasing Agent will check the SAMS Debarment and Suspension website on an annual basis. Results from this annual check will be logged and shared with both the Treasurer and Chief Business and Financial Officer and will be available for access by auditors or the public. Ineligible vendors, as noted on the SAMS website, will be removed from the District's financial management system. Implementation Date - Effective immediately.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of the District’s vendors charged to the fund, and none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: The Bethlehem Central School District appreciates the requirements of 2 CFR Section 200.213. The District's recent review of vendors indicated that there weren't any instances of ineligibility for participation in Federal assistance programs. To ensure formalized compliance, the District is updating procurement procedures which will highlight that the Purchasing Agent will check the SAMS Debarment and Suspension website on an annual basis. Results from this annual check will be logged and shared with both the Treasurer and Chief Business and Financial Officer and will be available for access by auditors or the public. Ineligible vendors, as noted on the SAMS website, will be removed from the District's financial management system. Implementation Date - Effective immediately.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of the District’s vendors charged to the fund, and none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: The Bethlehem Central School District appreciates the requirements of 2 CFR Section 200.213. The District's recent review of vendors indicated that there weren't any instances of ineligibility for participation in Federal assistance programs. To ensure formalized compliance, the District is updating procurement procedures which will highlight that the Purchasing Agent will check the SAMS Debarment and Suspension website on an annual basis. Results from this annual check will be logged and shared with both the Treasurer and Chief Business and Financial Officer and will be available for access by auditors or the public. Ineligible vendors, as noted on the SAMS website, will be removed from the District's financial management system. Implementation Date - Effective immediately.
Child Nutrition Cluster - Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, School Lunch Program Supply Chain- COVID 19 Assistance Listing numbers 10.553 and 10.555) passed through the New York State Education Department. Criteria: 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of the District’s vendors charged to the fund, and none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Views of the Responsible Officials and Planned Corrective Actions: The Bethlehem Central School District appreciates the requirements of 2 CFR Section 200.213. The District's recent review of vendors indicated that there weren't any instances of ineligibility for participation in Federal assistance programs. To ensure formalized compliance, the District is updating procurement procedures which will highlight that the Purchasing Agent will check the SAMS Debarment and Suspension website on an annual basis. Results from this annual check will be logged and shared with both the Treasurer and Chief Business and Financial Officer and will be available for access by auditors or the public. Ineligible vendors, as noted on the SAMS website, will be removed from the District's financial management system. Implementation Date - Effective immediately.
2024-005 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. In addition, the District does not have any procedures in place to verify purchases against the bidding documents for pricing. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. The District could also be overpaying for goods as the bid documentation is not being verified against the purchases made. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. As part of the current Child Nutrition testing, certain vendors were tested with their purchases being agreed back to the bidding documentation obtained. Some instances, the items were not listed on the bidding documentation or the prices paid were higher than the bid price. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. The District should also implement procedures to verify their purchases against bidding documentation to ensure that they are paying the correct, bid upon price for their purchases. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
2024-005 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. In addition, the District does not have any procedures in place to verify purchases against the bidding documents for pricing. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. The District could also be overpaying for goods as the bid documentation is not being verified against the purchases made. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. As part of the current Child Nutrition testing, certain vendors were tested with their purchases being agreed back to the bidding documentation obtained. Some instances, the items were not listed on the bidding documentation or the prices paid were higher than the bid price. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. The District should also implement procedures to verify their purchases against bidding documentation to ensure that they are paying the correct, bid upon price for their purchases. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
2024-005 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. In addition, the District does not have any procedures in place to verify purchases against the bidding documents for pricing. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. The District could also be overpaying for goods as the bid documentation is not being verified against the purchases made. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. As part of the current Child Nutrition testing, certain vendors were tested with their purchases being agreed back to the bidding documentation obtained. Some instances, the items were not listed on the bidding documentation or the prices paid were higher than the bid price. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. The District should also implement procedures to verify their purchases against bidding documentation to ensure that they are paying the correct, bid upon price for their purchases. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
2024-005 Child Nutrition Cluster - Procurement Information on Federal Program: U.S Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, and Special Milk Program for Children CFDA No. 10.553, 10.555, and 10.556) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and reverification of use of same vendors as previous year, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. They are however, checking the status of any new vendors. In addition, the District does not have any procedures in place to verify purchases against the bidding documents for pricing. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. The District could also be overpaying for goods as the bid documentation is not being verified against the purchases made. Questioned Costs: None Perspective Information: As part of required follow up of prior year audit findings, a review of vendors charged to the school lunch fund and therefore represent purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. As part of the current Child Nutrition testing, certain vendors were tested with their purchases being agreed back to the bidding documentation obtained. Some instances, the items were not listed on the bidding documentation or the prices paid were higher than the bid price. Repeat Finding: Yes Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. The District should also implement procedures to verify their purchases against bidding documentation to ensure that they are paying the correct, bid upon price for their purchases. Views of the Responsible Officials and Planned Corrective Actions: The District will monitor vendors to ensure they are able to accept federal monies.
Federal Agency: United States Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977 Award Period: July 1, 2023 – June 30, 2025 Federal Agency: United States Department of the Treasury Federal Program Name: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Direct Award: $7,065,073 Pass-Through Agency Award: State of Connecticut Office of Policy and Management: $2,305,990 Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City of Norwich did not have adequate internal controls designed to ensure vendors were not suspended or debarred in accordance with 2 CFR section 200.213. Questioned costs: N/A Context: It was noted that the vendors tested were not on the suspended or debarred vendor list maintained by the General Services Administration. However, there was no documentation for 8 out of the 9 vendors tested that the City reviewed the vendors’ status prior to awarding the contract. Cause: The Board of Education did not retain documentation of their review that the vendor were not suspended or debarred. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the City of Norwich design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred in accordance with 2 CFR section 200.213. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United States Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977 Award Period: July 1, 2023 – June 30, 2025 Federal Agency: United States Department of the Treasury Federal Program Name: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Direct Award: $7,065,073 Pass-Through Agency Award: State of Connecticut Office of Policy and Management: $2,305,990 Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City of Norwich did not have adequate internal controls designed to ensure vendors were not suspended or debarred in accordance with 2 CFR section 200.213. Questioned costs: N/A Context: It was noted that the vendors tested were not on the suspended or debarred vendor list maintained by the General Services Administration. However, there was no documentation for 8 out of the 9 vendors tested that the City reviewed the vendors’ status prior to awarding the contract. Cause: The Board of Education did not retain documentation of their review that the vendor were not suspended or debarred. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the City of Norwich design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred in accordance with 2 CFR section 200.213. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United States Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977 Award Period: July 1, 2023 – June 30, 2025 Federal Agency: United States Department of the Treasury Federal Program Name: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Direct Award: $7,065,073 Pass-Through Agency Award: State of Connecticut Office of Policy and Management: $2,305,990 Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City of Norwich did not have adequate internal controls designed to ensure vendors were not suspended or debarred in accordance with 2 CFR section 200.213. Questioned costs: N/A Context: It was noted that the vendors tested were not on the suspended or debarred vendor list maintained by the General Services Administration. However, there was no documentation for 8 out of the 9 vendors tested that the City reviewed the vendors’ status prior to awarding the contract. Cause: The Board of Education did not retain documentation of their review that the vendor were not suspended or debarred. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the City of Norwich design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred in accordance with 2 CFR section 200.213. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: United States Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Education Pass-Through Number(s): 12060-SDE64370-20977 Award Period: July 1, 2023 – June 30, 2025 Federal Agency: United States Department of the Treasury Federal Program Name: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Direct Award: $7,065,073 Pass-Through Agency Award: State of Connecticut Office of Policy and Management: $2,305,990 Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement, suspension, and debarment. Condition: The City of Norwich did not have adequate internal controls designed to ensure vendors were not suspended or debarred in accordance with 2 CFR section 200.213. Questioned costs: N/A Context: It was noted that the vendors tested were not on the suspended or debarred vendor list maintained by the General Services Administration. However, there was no documentation for 8 out of the 9 vendors tested that the City reviewed the vendors’ status prior to awarding the contract. Cause: The Board of Education did not retain documentation of their review that the vendor were not suspended or debarred. Effect: We noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: No Recommendation: We recommend the City of Norwich design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred in accordance with 2 CFR section 200.213. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
Finding 2024-001 Material Weakness, Compliance and Internal Control Over Procurement, Suspension and Debarment Compliance CFDA 93.676 - Unaccompanied Children Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Global Refuge and Lutheran Immigration and Refugee Services Criteria Or Specific Requirement: The organization must adhere to the procurement methods outlined in 2 CFR 200.320, using informal procedures for small purchases, formal methods (sealed bids or proposals) for larger ones, or noncompetitive methods as appropriate. The organization is responsible for establishing processes and procedures for each method and maintaining relevant documentation. Additionally, as per 2 CFR 200.213, the organization must not contract with suspended or debarred parties. Before entering into a covered transaction, the organization must verify the eligibility of the potential contractor. Condition: The Organization has not ensured compliance with appropriate procurement methods, retention of necessary documents and decisions, or pre-contractual review for suspension and debarment requirements. Cause: The Organization lacks sufficient policies and controls to ensure compliance with Federal procurement, suspension, and debarment regulations. Effect: The Organization's failure to fully comply with procurement, suspension and debarment requirements could have led to contracts with suspended or debarred parties or contracts awarded through improper methods. Questioned Costs: Not applicable Context: Three of the five contracts reviewed lacked sufficient documentation to support the procurement methodology used. While no payments were made to debarred parties, the absence of a policy or procedure to prevent such occurrences poses a significant risk. Identification As A Repeat Finding: N/A Recommendation: We recommend that Organization implement internal policies to identify appropriate procurement methodologies, conduct regular suspension and debarment checks, maintain adequate file documentation to ensure compliance with procurement and suspension/debarment regulations and prevent contracts with ineligible parties. Views Of Responsible Officials And Planned Corrective Action: The Organization agrees with the finding and has put together a corrective action plan for the finding. See corrective action plan included in this report.
Criteria: Southwest Counseling Services must design internal controls to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Per review of 2 CFR 200.213, non-Federal entities are prohibited from contracting with, or making sub-awards under covered transactions to, parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Condition/context: For one of the contracts selected for testing, we determined that the contractor did not have a suspension and debarment clause in the contract, and Southwest Counseling Services did not keep record of other verification procedures to document the subrecipient was not suspended or debarred. Independently, we verified that the contractor was not suspended or debarred. Cause: Southwest Counseling Services does not have a control system in place to ensure required suspension and debarment is verified and documented. Effect: Without processes and controls in place, it is possible that Southwest Counseling could contract with a contractor that is suspended or debarred. Questioned costs: None. Identification as a repeat finding: No Recommendation: We recommend that Southwest Counseling Services implement processes and controls to ensure compliance with the suspension and debarment requirement.
Finding 2024-004: Suspension and Debarment (Significant Deficiency) Information on the Federal Program: 45.301 - Institute of Museum and Library Services Criteria: Under 2 CFR §200.213, 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; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over Suspension and Debarment, we determined that the Museum did not perform screenings on the vendors selected for testing.Cause: The Museum does not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment occurs) potential and current vendors, suppliers, contractors and employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We noted that vendors, suppliers, contractors and employees selected for testing did not have a formally documented Suspension and Debarment check conducted prior to engagement. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. This policy should include a threshold for when vendors, suppliers, contractors and employees should be screened. All screenings should be conducted prior to signing a contract or issuing payment. We recommend that the Museum notify all employees of this policy and ensure that it is enforced during the upcoming fiscal year.
Criteria: In accordance with 2 CFR §200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. Additionally, §200.318(i) states that the nonfederal entity must maintain records sufficient to detail the history of the procurement. These records are required to 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. In accordance with §200.213 and §180.300, Suspension and Debarment, non-federal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Nonfederal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our testing of the procurement, suspension and debarment compliance requirements, we identified one procurement sample out of a total of two tested where the Organization did not have documented controls over the application of their procurement policy. Additionally, the Organization did not retain documentation of controls over their verification that the vendor contracted was not suspended or debarred prior to entering into contract with the vendor. Management has subsequently determined that the vendor was not suspended or debarred. Questioned Costs: None. Context: The population consisted of two vendor contracts entered into during the period subject to procurement. Both items were tested, one of which had no exceptions in testing and the other had the exceptions identified in the condition above. Cause: NGA Center's personnel did not adhere to NGA Center's documented policies and procedures for ensuring proper suspension and debarment validations were performed prior to entering a covered transaction and did not retain proper documentation supporting procurement controls.
Reference Number: 2024-002 Federal Agency: U.S. Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds (American Rescue Plan Act) Assistance Listing Number: 21.027 Federal Award Identification Number Not Available Federal Award Year 2024 Pass-Through Agency: N/A Pass-Through Number: N/A Compliance Requirement: Suspension and Debarment Award Period: 7/1/2023 - 6/30/2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters 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 County could not provide supporting documentation that suspension and debarment status was determined prior to award. Context: The suspension and debarment status for three out of seven vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: The County 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 County is not in compliance with federal suspension and debarment regulations. Repeat Finding: The finding is a repeat of a finding in the immediate prior year. Prior year finding number was 2023-001. Recommendation: The County 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 County regularly checks Sam.gov for suspension and debarment transactions. We relied on state policies and procedures regarding the contracts in question as they were piggyback contracts. Moving forward, we will ensure thorough documentation of our reviews to maintain diligence in this area.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 and 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement 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. Condition and Context: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 and 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement 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. Condition and Context: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 and 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement 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. Condition and Context: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555 and 10.559 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education Pass-Through Number(s): 09-100 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement 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. Condition and Context: For the four vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2023 – June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement 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. Condition and Context: For the two vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes (Finding 2023-001) Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal agency: U.S. Department of Education Federal program title: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Pass-Through Agency: Massachusetts Department of Elementary and Secondary Education and Massachusetts Department of Early Education and Care Pass-Through Number(s): Various (see Schedule of Expenditures of Federal Awards) Award Period: July 1, 2023 – June 30, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.213 states that nonfederal entities are subject to the nonprocurement 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. Condition and Context: For the two vendors in our statistically valid sample, documentation was not provided to support that the City verified the vendors were not debarred or suspended from participation in Federal assistance programs or activities. Questioned Costs: None Cause: Procedures were not in place to document the verification that all vendors were not suspended or debarred from participation in Federal assistance programs or activities. Effect: While this did not occur in the instance identified in this finding, lack of verification of vendors’ debarment or suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in Federal assistance programs or activities. Repeat Finding: Yes (Finding 2023-001) Recommendation: We recommend procedures be implemented to document the verification that all vendors are not suspended or debarred from participation in Federal assistance programs or activities. Views of Responsible Officials: Management agrees with the finding.
Federal Agency: Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A, 2024 Award Period: 7/1/2023-6/30/2024 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 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: a) Checking SAM Exclusions; or b) Collecting a certification from that person; or c) Adding a clause or condition to the covered transaction with that person. Internal 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 City was unable to provide documentation of a vendor’s suspension and debarment status. The City is required to review and document a vendor’s suspension and debarment status prior to contracting with the vendor. We noted that the City did not document the vendor’s status in accordance with the federal requirements. Questioned Costs: None Context: Two of the two vendors selected for the fiscal year 2024 testing did not have evidence of the vendor’s suspension and debarment status prior to the contract date. Cause: The contractors selected for testing were not updated to include the suspension and debarment clause. Effect: The City is unable to document compliance with suspension and debarment status prior to contracting with the vendor. Repeat Finding: No Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor’s suspension and debarment status is documented prior to contracting with the vendor. Views of Responsible Officials: There is no disagreement with the audit finding and new personnel in the Department of Community and Human Services will ensure that all required monitoring is performed and documented in a timely manner.
Federal Agency: Department of Health and Human Services Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A, 2024 Award Period: 7/1/2023-6/30/2024 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 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: a) Checking SAM Exclusions; or b) Collecting a certification from that person; or c) Adding a clause or condition to the covered transaction with that person. Internal 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 City was unable to provide documentation of a vendor’s suspension and debarment status. The City is required to review and document a vendor’s suspension and debarment status prior to contracting with the vendor. We noted that the City did not document the vendor’s status in accordance with the federal requirements. Questioned Costs: None Context: Two of the two vendors selected for the fiscal year 2024 testing did not have evidence of the vendor’s suspension and debarment status prior to the contract date. Cause: The contractors selected for testing were not updated to include the suspension and debarment clause. Effect: The City is unable to document compliance with suspension and debarment status prior to contracting with the vendor. Repeat Finding: No Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor’s suspension and debarment status is documented prior to contracting with the vendor. Views of Responsible Officials: There is no disagreement with the audit finding and new personnel in the Department of Community and Human Services will ensure that all required monitoring is performed and documented in a timely manner.