NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2024 Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition 1: The county did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Condition 2: The county did not formally bid a communications upgrade pre-install project as required by federal procurement standards established in 2 CFR 300.19. Cause: The county does not have procurement policies and procedures in place that allows it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21.027, Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - SLFRP 2024-2001 Pass-through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180.300 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The City could not provide evidence that it complied with the above regulations. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - Recipients of federal awards must have procedures in place to verify that a contractor with which they plan to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause and Effect - The City did not have a procedure in place to review contractors and entered into covered agreements without knowing whether the contractors were debarred, suspended, or otherwise excluded. Recommendation - We recommend that an additional internal process be put in place to ensure all vendors utilized with federal funds are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The City will ensure that all future contracts awarded under this program are in compliance and will have contractors sign to verify that they are in compliance.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
2024-001: Suspension and Debarment Program: Child and Adult Care Food Program (ALN 10.558) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Maryland State Department of Education (347105) District of Columbia OSSE (N/A) Virginia Department of Health (4108) Federal Award Year: Year ended June 30, 2024 Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: District of Columbia Department of Health (CHA2022-000027) Montgomery County Department of Health and Human Services (1087608) Maryland Department of Aging (N/A) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster) Federal agency: U.S. Department of Agriculture Pass-through entity name and identifying number: Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24) Federal Award Year: Year ended June 30, 2024 Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster) Pass-through entity name and identifying number: District of Columbia OSSE Wellness and Nutrition Services Division (CW102461) District of Columbia Department of Health (N/A) Virginia Department of Agriculture and Consumer Services (VDACS) (67-150) Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012) Federal agency: U.S. Department of Agriculture Federal Award Year: Year ended June 30, 2024 Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027) Federal agency: U.S. Department of the Treasury Pass-through entity name and identifying number: Federation of Virginia Food Banks (N/A) Federation of Virginia Food Banks – Farms to Families Box Program (N/A) Fairfax County (#SR-003432J) D.C. Department of Health (CHA2022-000020-1) Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED) City of Falls Church (N/A) VA Department of Agricultural Services (2022-4A1-001) Prince William County (N/A) Federal Award Year: Year ended June 30, 2024 Type of finding: Material Weakness in Internal Control over Compliance Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement. Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs. Cause: The review process related to suspension and debarment did not occur as intended. Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties. Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred. Questioned costs: None Repeat finding: No Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed. Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.
Assistance Listing Number #21.027 - Coronavirus State and Local Fiscal Recovery Funds. Type of Finding: Significant deficiency in internal control over major federal programs. Criteria: The Uniform GuidanCriteria: The Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) 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., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We noted that BRAG does not have a process to check for suspension and debarment. Cause: BRAG staff are not familiar with federal suspension and debarment requirements. Effect or Potential Effect: BRAG has a significant deficiency in internal control with respect to its procurement policies and procedures, which could result in significant noncompliance or questioned costs in the future. Recommendation: BRAG management should ensure that procurement policies and procedures regarding the expenditure of federal funds are updated to address suspension and debarment and that these policies and procedures are being following by all BRAG personnel. In addition, we recommend that BRAG management provide training related to procurement policies and procedures to all BRAG personnel with the ability to enter into a contract.
Assistance Listing Number #21.027 - Coronavirus State and Local Fiscal Recovery Funds. Type of Finding: Significant deficiency in internal control over major federal programs. Criteria: The Uniform GuidanCriteria: The Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) 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., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We noted that BRAG does not have a process to check for suspension and debarment. Cause: BRAG staff are not familiar with federal suspension and debarment requirements. Effect or Potential Effect: BRAG has a significant deficiency in internal control with respect to its procurement policies and procedures, which could result in significant noncompliance or questioned costs in the future. Recommendation: BRAG management should ensure that procurement policies and procedures regarding the expenditure of federal funds are updated to address suspension and debarment and that these policies and procedures are being following by all BRAG personnel. In addition, we recommend that BRAG management provide training related to procurement policies and procedures to all BRAG personnel with the ability to enter into a contract.
Criteria: 2 CFR 200.319 states that all procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with Federal procurement standards. 2 CFR 200.214 states in part that recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations. In addition, 2 CFR 200.303 in part states that a recipient of a Federal award must establish, document, and maintain effective internal control over the Federal award. Condition: We have selected and tested three of the largest vendors from the Child Nutrition Cluster for compliance with procurement and suspension and debarment. We identified that one vendor was not properly procured, in accordance with 2 CFR 200.319–2 CFR 200.324. As a result, the District incurred questioned costs in the amount of $31,401.63, which was in excess of $25,000 Federal requirement, based on 2 CFR 200.516. Also, the District did not perform procedures to verify suspension and debarment on the same vendor. Cause: District’s internal controls over procurement in the Child Nutrition Cluster were properly designed but not operating effectively to verify that all vendors are properly procured and verified for suspension and debarment. The District did not properly procure one vendor within the Child Nutrition Cluster that incurred questioned costs in excess of the $25,000 threshold, based on 2 CFR 200.516. Effect: The District did not properly procure one vendor within the Child Nutrition Cluster that incurred questioned costs in excess of the $25,000 threshold, based on 2 CFR 200.516, and, as a result, revealed a significant deficiency in internal controls over procurement in the Child Nutrition Cluster. Repeat Finding: No. Recommendation: We recommend that the District re-evaluate the procurement processes in the Child Nutrition Services program and re-evaluate the design of internal controls over procurement and suspension and debarment to be in compliance with the Federal requirements and the District’s procurement policy.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-005 Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Names: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-152114-DPI-FLOW-341, 2024-152114-DPI-PRESCH-347 Type of Finding Significant Deficiency in internal control over compliance Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition The District could not provide proof of verification of the suspension and debarment status of vendors before entering into services with them. Questioned Costs None. Context The District did not document their review 1 of 1 vendors tested in our sample to document they were not suspended or debarred when initiating covered transactions in the current year. Cause The District does not have a policy or procedure in place to document if a vendor is debarred or suspended. Effect The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding – No Section III – Federal Award Findings and Questioned Costs (Continued) 2024-005 (Continued) Recommendation We recommend the District establish procedures that are in accordance with Uniform Guidance to document their verification that the vendor is not suspended or debarred at the beginning of the year or before entering into a contract. Views of Responsible Officials There is no disagreement with this finding.
2024-005 Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Names: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027, 84.173 Federal Award Year: 2023-2024 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Numbers: 2024-152114-DPI-FLOW-341, 2024-152114-DPI-PRESCH-347 Type of Finding Significant Deficiency in internal control over compliance Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition The District could not provide proof of verification of the suspension and debarment status of vendors before entering into services with them. Questioned Costs None. Context The District did not document their review 1 of 1 vendors tested in our sample to document they were not suspended or debarred when initiating covered transactions in the current year. Cause The District does not have a policy or procedure in place to document if a vendor is debarred or suspended. Effect The District could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding – No Section III – Federal Award Findings and Questioned Costs (Continued) 2024-005 (Continued) Recommendation We recommend the District establish procedures that are in accordance with Uniform Guidance to document their verification that the vendor is not suspended or debarred at the beginning of the year or before entering into a contract. Views of Responsible Officials There is no disagreement with this finding.
Criteria: Per 2 CFR 200.214, when an entity enters into a covered transaction using federal awards with a vendor, the entity must verify that the vendor is not debarred, suspended, or otherwise excluded from receiving or participating in Federal award. The entity can do this by: (a) Checking SAM.gov Exclusions; or (b) Collecting a certification from that entity; or (c) Adding a clause or condition to the covered transaction Condition: C/CAG was unable to provide proof that it performed a suspension and debarment check on one of two vendors tested. C/CAG did not have evidence of a SAM.gov check on the vendor, or a timely certification from that vendor, or a clause or condition in the contract with that vendor asserting they were not suspended or debarred. Cause: The vendor had been selected for an earlier similar non-Federally-funded project, and the new amended contract did not include the suspension/debarment clause as required by C/CAG’s policy. Effect: One vendor of two tested vendors did not have sufficient evidence that they were not debarred or suspended from participating in Federal award activities.
2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: Massachusetts Department of Revenue Pass-Through Number: ARPACNTYSH056 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Compliance Requirement: Suspension and Debarment Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 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. Nonfederal entities must verify that contracts with certain parties are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition and Context: For three vendors in our audit sample, the Town did not document verification that the vendor was not suspended or debarred from participation in Federal assistance programs or activities. The vendors in our audit sample were not suspended or debarred. 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 instances 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 to annually (at a minimum) 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.
Finding 2024-003: Procurement, Suspension, and Debarment Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.395, 93.866 Title: Cancer Treatment Research, Aging Research Award Year: 3/1/2019-11/30/2023, 2/15/2021-1/31/2026 Award #: 3UM1CA18670405S1, 5R01AG07094105 Criteria: -2 CFR 200, Subpart D which require institutions to (1) maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services; (2) maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. -2 CFR 200.214 which restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: -For 2 of 25 procurements sampled, the University documented both supplier justification and the purchase order after receipt of an invoice from the vendor. -For 1 of 25 procurements sampled, the University did not maintain evidence of their price/cost analysis as requires when the procurement exceeds the simplified acquisition threshold of $250,000. -For 1 of 25 samples selected for suspension and debarment, the University performed the suspension/debarment screen after the date and payment of the vendor invoice. Cause: For vendors that existed in the legacy accounting system, the University has not consistently documented vendor screening results. Additionally, procurement decisions/conclusions were not consistently documented prior to executing transactions with vendors. Effect: There is a risk that the University could enter into transactions with vendors that are suspended/debarred. Separately, failure to document procurement decisions in a timely manner could impact the University's ability to demonstrate compliance with federal regulations and the University's procurement policies. Questioned Costs: There are no questioned costs as the vendor selected was not suspended or debarred and procurement transactions were deemed allowable. Recommendation: Management should enhance its existing processes to ensure all decisions and conclusions supporting procurements are made in a timely manner and completely documented in the procurement files prior to entering into transactions with vendors. The University should also ensure that all required suspension and debarment checks are performed, and documentation is maintained in advance of transacting with vendors. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.
Finding 2024-003: Procurement, Suspension, and Debarment Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.395, 93.866 Title: Cancer Treatment Research, Aging Research Award Year: 3/1/2019-11/30/2023, 2/15/2021-1/31/2026 Award #: 3UM1CA18670405S1, 5R01AG07094105 Criteria: -2 CFR 200, Subpart D which require institutions to (1) maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services; (2) maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. -2 CFR 200.214 which restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: -For 2 of 25 procurements sampled, the University documented both supplier justification and the purchase order after receipt of an invoice from the vendor. -For 1 of 25 procurements sampled, the University did not maintain evidence of their price/cost analysis as requires when the procurement exceeds the simplified acquisition threshold of $250,000. -For 1 of 25 samples selected for suspension and debarment, the University performed the suspension/debarment screen after the date and payment of the vendor invoice. Cause: For vendors that existed in the legacy accounting system, the University has not consistently documented vendor screening results. Additionally, procurement decisions/conclusions were not consistently documented prior to executing transactions with vendors. Effect: There is a risk that the University could enter into transactions with vendors that are suspended/debarred. Separately, failure to document procurement decisions in a timely manner could impact the University's ability to demonstrate compliance with federal regulations and the University's procurement policies. Questioned Costs: There are no questioned costs as the vendor selected was not suspended or debarred and procurement transactions were deemed allowable. Recommendation: Management should enhance its existing processes to ensure all decisions and conclusions supporting procurements are made in a timely manner and completely documented in the procurement files prior to entering into transactions with vendors. The University should also ensure that all required suspension and debarment checks are performed, and documentation is maintained in advance of transacting with vendors. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.
Criteria or specific requirement: 2 CFR 200.214 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 Per 2 CFR 200.303, non-federal entities receiving federal awards 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: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed suspension and debarment verification procedures before the start of procurement contracts for twelve contracts of a total of twenty-eight selections (43%) tested. Questioned costs: None. Context: Twenty-eight transactions were selected for testing which included fifteen contracts and thirteen subawards. For twelve of fifteen contracts (80%), the Department was unable to provide documentation supporting when it had verified the contractors’ suspension and debarment status. The Department provided auditors with documentation that the contractors were not suspended or debarred, however, auditors were not able to verify that the status was documented prior to the start of the contracts. No exceptions were noted for the thirteen subawards tested. Cause: The Department’s procedures and internal controls are not sufficient to ensure that it verifies and properly documents contractors’ suspension and debarment status prior to the execution of contracts. Effect: Failure to perform suspension and debarment verification procedures before the procurement of good or services could result in the payment of federal funds to contractors that are ineligible to participate in federal assistance programs. Repeat Finding: Yes, Finding 2023 – 008. Recommendation: We recommend that the Department enhance its procedures and internal controls to ensure that it verifies and maintains documentation of its contractors’ suspension and debarment status prior to the execution of all contracts. Verification can be performed by either checking SAM exclusions and maintaining documentation when the verification occurred, collecting a signed certification from the contractor prior to contract execution, or adding a clause or condition to the contract. We further recommend that documentation is readily available for audit. Views of responsible officials: Management disagrees with this finding. KDHE disagrees with this finding. KDHE has an established process in place which is documented in the Procurement Policies and Procedures manual that was provided as part of the audit request which shows that verification of suspension and debarment in the System for Award Management takes place prior to contractual agreements being fully executed as part of the agency’s established process. There is no requirement that KDHE is aware of that requires that the date of verification be documented. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of SAM verification occurring prior to or the same time as the contract being signed was not provided.
Criteria or specific requirement: 2 CFR 200.214 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 Per 2 CFR 200.303, non-federal entities receiving federal awards 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: Kansas Department of Health and Environment (Department) was unable to provide supporting documentation that it had performed suspension and debarment verification procedures before the start of procurement contracts for twelve contracts of a total of twenty-eight selections (43%) tested. Questioned costs: None. Context: Twenty-eight transactions were selected for testing which included fifteen contracts and thirteen subawards. For twelve of fifteen contracts (80%), the Department was unable to provide documentation supporting when it had verified the contractors’ suspension and debarment status. The Department provided auditors with documentation that the contractors were not suspended or debarred, however, auditors were not able to verify that the status was documented prior to the start of the contracts. No exceptions were noted for the thirteen subawards tested. Cause: The Department’s procedures and internal controls are not sufficient to ensure that it verifies and properly documents contractors’ suspension and debarment status prior to the execution of contracts. Effect: Failure to perform suspension and debarment verification procedures before the procurement of good or services could result in the payment of federal funds to contractors that are ineligible to participate in federal assistance programs. Repeat Finding: Yes, Finding 2023 – 008. Recommendation: We recommend that the Department enhance its procedures and internal controls to ensure that it verifies and maintains documentation of its contractors’ suspension and debarment status prior to the execution of all contracts. Verification can be performed by either checking SAM exclusions and maintaining documentation when the verification occurred, collecting a signed certification from the contractor prior to contract execution, or adding a clause or condition to the contract. We further recommend that documentation is readily available for audit. Views of responsible officials: Management disagrees with this finding. KDHE disagrees with this finding. KDHE has an established process in place which is documented in the Procurement Policies and Procedures manual that was provided as part of the audit request which shows that verification of suspension and debarment in the System for Award Management takes place prior to contractual agreements being fully executed as part of the agency’s established process. There is no requirement that KDHE is aware of that requires that the date of verification be documented. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Evidence of SAM verification occurring prior to or the same time as the contract being signed was not provided.
Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year: SLFRP0923, March 3, 2021, through December 31, 2024 Federal Grantor Agency: U.S. Department of the Treasury Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.214 (January 1, 2024) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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 U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . .[entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. Condition: The County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented. We noted that the County used CSLFRF to pay three vendors over $25,000 each, totaling $1,294,743, during the fiscal year ended June 30, 2024. The County was unable to support that a review was performed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov (the “System for Award Management,” an official website of the U.S. Government) and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding: 2023-002 Questioned Costs: None Statistical Sample: No Context: The following table provides details of the covered transactions noted: Cause: Lack of procedures and knowledge regarding suspension and debarment requirements. Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials: Saline County will set up procedures to ensure reviews are performed to ensure vendors are not excluded or disqualified (SAM).
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027; Direct Allocation, YEAR ENDED JUNE 30, 2024 Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The county does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS, ASSISTANCE LISTING No. 66.458 Criteria: The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Further, per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, cities must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. Condition: The City did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the programs. Cause: The City does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027. Criteria: The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Further, per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, cities must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. Condition: The City did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the programs. Cause: The City does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027. Criteria: The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Further, per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, cities must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. Condition: The City did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the programs. Cause: The City does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027. Criteria: The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Further, per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, cities must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. Condition: The City did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the programs. Cause: The City does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027. Criteria: The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Further, per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, cities must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. Condition: The City did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the programs. Cause: The City does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2024 Criteria: Per Treasury’s Final Rule FAQs and 2 CFR 200.214, recipients are prohibited from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The county does not have procurement policies and procedures in place that allows it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.