U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT: 2022-026 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 See Compliance Finding 2022-021. 2022-021 Compliance with Financial and Performance Reporting Fiscal year finding initially occurred: 2021 CDBG ? Entitlement Grants Cluster (14.218) B-16-MC-22-0003, B-17-MC-22-0003, B-18-MC-22-0003, B-19-MC-22-0003, B-20-MC-22-0003, B-21-MC-22-0003, B-22-MC-22-0003 Criteria Pursuant to Part 4 CDBG ? Entitlement Grants Cluster and financial and performance reporting requirements in the cooperative agreement provisions, and 2 CFR 200.327. Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Auditor?s are only expected to test information extracted from IDIS in the following system-generated reports: (1) C04PR03 ? Activity Summary Report, (2) C04PR26 ? CDBG Financial Summary Report, (3) C04PR26 ? CDBG-CV Financial Summary Report, (4) C04PR26 ? CDBG Activity Summary by Selected Grant. Condition Instance of Non-Compliance ? While the CDBG Financial Summary Report (C04PR26) was submitted timely, the report included materially inaccurate information on line 30, Adjustment to Compute Total PS Obligations. The amount reported was overstated by $48,812. Cause The Government has not corrected the error in the reporting to the U.S. Department of Housing and Urban Development. Effect Noncompliance with financial reporting requirements. Recommendation We recommend the Government review its procedures over reporting to ensure that all required reporting information is reviewed and reconciled for accuracy to the Government?s financial records. Views of Responsible Officials and Planned Corrective Action The finding was a result of a clerical error. The Government is allowed to utilize up to 15% of its annual CDBG allocation for Public Services. The adjustment made was to correct the reported actual use from 2% to 5%. Corrective actions are being implemented to ensure data entered into the report is accurate prior to submission to HUD. This project is expected to be completed within three months and will be overseen by Community Development & Planning Director Mary Sliman.
Reference Number: 2022-001 Prior Year Finding: Yes – 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: Various Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of §§ 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: • Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. • The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
Reference Number: 2022-001 Prior Year Finding: Yes – 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: Various Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of §§ 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: • Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. • The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
Reference Number: 2022-001 Prior Year Finding: Yes – 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: Various Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of §§ 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: • Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. • The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
Reference Number: 2022-001 Prior Year Finding: Yes – 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: Various Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of §§ 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: • Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. • The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
Reference Number: 2022-001 Prior Year Finding: Yes – 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: Various Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of §§ 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: • Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. • The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
Reference Number: 2022-001 Prior Year Finding: Yes – 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: Various Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of §§ 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: • Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. • The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
Reference Number: 2022-001 Prior Year Finding: Yes – 2021-001 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Agency: Various Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per § 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR § 200.318 General procurement standards. We selected five (5) vendors for procurement Suspension and Debarment compliance testing of total population of 5 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: • To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. • To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of §§ 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: • Use documented procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. • The Division must maintain records sufficient to detail the history of procurement. These records should include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
Criteria The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in ??200.317 through 200.327. Condition The County did not have a written federal procurement policy and procedures throughout the majority of FY2022. The County adopted a written policy, in agreement with 2CFR200.318(a), on August 9, 2022. As of September 30, 2022, the adopted policy had not been fully implemented. Cause The County was unable to internally reconcile disagreements in the language for inclusion in the federal procurement policy and procedures document, leading to a delay in the approval and implementation of a written procurement policy. Effect The County would be out of compliance with the required procurement activities for purchases. Questioned Costs There are no questioned costs related to finding 2022-001. This is a general finding, rather than a finding related to a specific program. Perspective Information The County began working on a draft version of the written procurement policy in FY2021. The process of researching federal procurement requirements and reconciling the final language took longer than expected. Upon the adoption of the policy on August 9, 2022, the County began the implementation process. Within the language of the adopted policy are provisions which shall be vetted and discussed prior to taking effect. Such policies are noted as taking effect no later than August 4, 2023. This finding represents a systematic problem (as opposed to an isolated event), which is actively being resolved. Identification of Repeat Findings This is not a repeat finding. Recommendation We recommend the County expedite the provisions subject to vetting and begin following the written federal procurement policy and procedures. Views of Responsible Officials We agree with the audit finding and are taking corrective action to fully implement the policy on or before August 4, 2023. The county has officially formed an audit committee composed of the nine elected officials. The audit committee will review the federal procurement policy to ensure complete implementation.
Significant Deficiency 2 CFR ? 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR ? 200.302 (b) (6) and (7) which requires the Authority to establish written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles and the terms and conditions of the Federal award and establish written procedures to implement the requirements of ? 305 Payment. Additionally, 2 C.F.R. ? 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. ? 200.318(a) which states the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Although the Authority did have written standard operating procedures requiring purchase orders, they did not have an approved purchase order or contract on file for 2 of the 50 purchases tested. Failure to have proper controls in place to ensure policies and procedures are being followed could result in unallowable costs and procurement noncompliance. The Authority should follow their written standard operating procedures and implement controls to ensure allowability of costs and procurement in accordance with federal grants.
2022-004 Significant Deficiency in Internal Controls over Compliance for Procurement, Suspension and Debarment Identification data: U.S. Department of Agriculture (USDA) Water and Waste Disposal Systems for Rural Communities ? grants, Assistance Listing No. 10.760 Criteria: Part 2 CFR 300.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Additionally, the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition and Context: The Village of Clearwater, Nebraska does not have a formal documented policy regarding procurement, suspension, and debarment transactions. Additionally, the Village does not have a written standards of conduct covering conflicts of interest and governing the performance of its employees engaged in the selection, award, and administration of contracts. Cause: A breakdown in the Village?s internal controls over procurement, suspension and debarment did not allow the Village to comply with the standards. Effect or potential effect: The control deficiency is a significant deficiency that may prevent the Village from complying with the procurement, suspension, and debarment requirements of the award agreements. Recommendation: The Village?s management and Board should develop formal written policies and procedures for procurement, suspension and debarment transactions. Additionally, the Village should adopt written standards of conduct covering conflicts of interest. Views of Responsible Officials: The Village of Clearwater, Nebraska?s management and Board will work on developing formal written procedures for procurement, suspension and debarment transactions. Additionally, the Village will adopt written standards of conduct covering conflicts of interest.
Finding 2022 ? 001: Procurement and Suspension and Debarment for Federal Programs Significant Deficiency, Internal Control Over Compliance Assistance Listing Number: 93.591 ? COVID-19 Family Violence Prevention and Services/State Domestic Violence Coalitions / 16.575 ? Crime Victim Assistance Federal Agency: Department of Health and Human Services / Department of Justice Award Year: 2022 Federal Award Identification: 2101MSSDVC, 2101MSSDC6, 2001MSSDC3 (ALN: 93.671) Pass-Through Entity: Mississippi Department of Health (ALN: 93.671 and 16.575) Criteria: In accordance with 2 CFR 200.303 (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). The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. In addition procedures should conform to those detailed in 2 CFR 180.300 through 180.325: ?Responsibilities of Participants Regarding Transactions Doing Business With Other Persons?. Condition: Although no instance of non-compliance were identified, MCADV does not have internal controls in place to ensure compliance with this requirement. Cause: MCADV?s internal control system was not properly designed to ensure that contracting with suspended or debarred parties is prevented. Further, documentation was not available to demonstrate that a procurement policy was in place to address cost and price analysis and vendor selections, where applicable, based on the method of procurement used. MCADV historically contracts with the same vendors year-over-year and did not review the list of suspended or debarred entities to ensure current vendors were not on the suspension or debarment list. Effect: Although no instances of noncompliance were identified, MCADV?s lack of internal control process related to procurement and suspension and debarment, could result in violation of the federal requirement. Questioned Costs: N/A. Identification As A Repeat Finding: Yes. Recommendations: We recommend developing a procurement policy to guide the selection of vendors, further this policy should require the periodic review of vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Views Of Responsible Officials and Planned Corrective Action: MCADV will make the necessary correction for compliance. As a result of the finding, Wendy Mahoney will be responsible for developing a procurement policy to guide the selection of vendors. MCADV will ensure the policy includes the periodic review of those vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Anticipated completion date: September 30, 2023.
Finding 2022 ? 001: Procurement and Suspension and Debarment for Federal Programs Significant Deficiency, Internal Control Over Compliance Assistance Listing Number: 93.591 ? COVID-19 Family Violence Prevention and Services/State Domestic Violence Coalitions / 16.575 ? Crime Victim Assistance Federal Agency: Department of Health and Human Services / Department of Justice Award Year: 2022 Federal Award Identification: 2101MSSDVC, 2101MSSDC6, 2001MSSDC3 (ALN: 93.671) Pass-Through Entity: Mississippi Department of Health (ALN: 93.671 and 16.575) Criteria: In accordance with 2 CFR 200.303 (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). The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. In addition procedures should conform to those detailed in 2 CFR 180.300 through 180.325: ?Responsibilities of Participants Regarding Transactions Doing Business With Other Persons?. Condition: Although no instance of non-compliance were identified, MCADV does not have internal controls in place to ensure compliance with this requirement. Cause: MCADV?s internal control system was not properly designed to ensure that contracting with suspended or debarred parties is prevented. Further, documentation was not available to demonstrate that a procurement policy was in place to address cost and price analysis and vendor selections, where applicable, based on the method of procurement used. MCADV historically contracts with the same vendors year-over-year and did not review the list of suspended or debarred entities to ensure current vendors were not on the suspension or debarment list. Effect: Although no instances of noncompliance were identified, MCADV?s lack of internal control process related to procurement and suspension and debarment, could result in violation of the federal requirement. Questioned Costs: N/A. Identification As A Repeat Finding: Yes. Recommendations: We recommend developing a procurement policy to guide the selection of vendors, further this policy should require the periodic review of vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Views Of Responsible Officials and Planned Corrective Action: MCADV will make the necessary correction for compliance. As a result of the finding, Wendy Mahoney will be responsible for developing a procurement policy to guide the selection of vendors. MCADV will ensure the policy includes the periodic review of those vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Anticipated completion date: September 30, 2023.
Finding 2022 ? 001: Procurement and Suspension and Debarment for Federal Programs Significant Deficiency, Internal Control Over Compliance Assistance Listing Number: 93.591 ? COVID-19 Family Violence Prevention and Services/State Domestic Violence Coalitions / 16.575 ? Crime Victim Assistance Federal Agency: Department of Health and Human Services / Department of Justice Award Year: 2022 Federal Award Identification: 2101MSSDVC, 2101MSSDC6, 2001MSSDC3 (ALN: 93.671) Pass-Through Entity: Mississippi Department of Health (ALN: 93.671 and 16.575) Criteria: In accordance with 2 CFR 200.303 (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). The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. In addition procedures should conform to those detailed in 2 CFR 180.300 through 180.325: ?Responsibilities of Participants Regarding Transactions Doing Business With Other Persons?. Condition: Although no instance of non-compliance were identified, MCADV does not have internal controls in place to ensure compliance with this requirement. Cause: MCADV?s internal control system was not properly designed to ensure that contracting with suspended or debarred parties is prevented. Further, documentation was not available to demonstrate that a procurement policy was in place to address cost and price analysis and vendor selections, where applicable, based on the method of procurement used. MCADV historically contracts with the same vendors year-over-year and did not review the list of suspended or debarred entities to ensure current vendors were not on the suspension or debarment list. Effect: Although no instances of noncompliance were identified, MCADV?s lack of internal control process related to procurement and suspension and debarment, could result in violation of the federal requirement. Questioned Costs: N/A. Identification As A Repeat Finding: Yes. Recommendations: We recommend developing a procurement policy to guide the selection of vendors, further this policy should require the periodic review of vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Views Of Responsible Officials and Planned Corrective Action: MCADV will make the necessary correction for compliance. As a result of the finding, Wendy Mahoney will be responsible for developing a procurement policy to guide the selection of vendors. MCADV will ensure the policy includes the periodic review of those vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Anticipated completion date: September 30, 2023.
Finding 2022 ? 001: Procurement and Suspension and Debarment for Federal Programs Significant Deficiency, Internal Control Over Compliance Assistance Listing Number: 93.591 ? COVID-19 Family Violence Prevention and Services/State Domestic Violence Coalitions / 16.575 ? Crime Victim Assistance Federal Agency: Department of Health and Human Services / Department of Justice Award Year: 2022 Federal Award Identification: 2101MSSDVC, 2101MSSDC6, 2001MSSDC3 (ALN: 93.671) Pass-Through Entity: Mississippi Department of Health (ALN: 93.671 and 16.575) Criteria: In accordance with 2 CFR 200.303 (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). The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. In addition procedures should conform to those detailed in 2 CFR 180.300 through 180.325: ?Responsibilities of Participants Regarding Transactions Doing Business With Other Persons?. Condition: Although no instance of non-compliance were identified, MCADV does not have internal controls in place to ensure compliance with this requirement. Cause: MCADV?s internal control system was not properly designed to ensure that contracting with suspended or debarred parties is prevented. Further, documentation was not available to demonstrate that a procurement policy was in place to address cost and price analysis and vendor selections, where applicable, based on the method of procurement used. MCADV historically contracts with the same vendors year-over-year and did not review the list of suspended or debarred entities to ensure current vendors were not on the suspension or debarment list. Effect: Although no instances of noncompliance were identified, MCADV?s lack of internal control process related to procurement and suspension and debarment, could result in violation of the federal requirement. Questioned Costs: N/A. Identification As A Repeat Finding: Yes. Recommendations: We recommend developing a procurement policy to guide the selection of vendors, further this policy should require the periodic review of vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Views Of Responsible Officials and Planned Corrective Action: MCADV will make the necessary correction for compliance. As a result of the finding, Wendy Mahoney will be responsible for developing a procurement policy to guide the selection of vendors. MCADV will ensure the policy includes the periodic review of those vendors against the federal list of suspensions and debarments published on the System for Award Management website at https://sam.gov/content/exclusions. Anticipated completion date: September 30, 2023.
Identification of federal program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Department of the Treasury Criteria or specific requirement: 21.027 Part 4 Compliance Supplement: Procurement - Recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined in sections 602(c) and 603(c) of the Act and Treasury?s Interim Final Rule. As such, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. All other entities under the program, including subrecipients of a state, must follow the procurement standards in 2 CFR 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR 200.320. Uniform Guidance 2 C.F.R 200.318 through 2 C.F.R. 200.327 200.318(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.200.318(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: It was noted during the audit of fiscal year 2022 that although Skagway Traditional Council (STC) has documented procurement policies consistent with Uniform Guidance. STC did not maintain evidence that it followed its own documented procurement policy for procurements greater than the micro-purchase threshold. Cause: STC does not have an administrative process to ensure that the procurement documentation supporting purchases greater than the micro-purchase threshold are maintained in accordance with STCs procurement policies. Effect or potential effect: STC is out of compliance with Uniform Guidance procurement standards in fiscal year 2022. Questioned Costs: None. Context: For this program, four procurements were greater than STC?s micro-purchase threshold and all four were tested against STC?s procurement policy, of those four, none of them had documentation supporting STC following STC?s procurement policies. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of STC?s internal control structure over compliance with Uniform Guidance, that STC prepare a checklist, reflective of STC?s approved procurement policies, that must be completed before procurements can be awarded and all documents supporting that checklist be filled together. Views of Responsible Officials: See Corrective Action Plan
THE SALVATION ARMY USA, WESTERN TERRITORY, DEL ORO DIVISION SCHEDULE OF FINDINGS AND QUESTIONED COSTS SEPTEMBER 30, 2022 Reference Number: 2022-001 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: State of California- Department of Housing and Community Development Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per ? 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR ? 200.318 General procurement standards. We selected two (2) vendors for procurement Suspension and Debarment compliance testing of total population of 2 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: ? To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. ? To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of ?? 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: (1) document procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division?s documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
THE SALVATION ARMY USA, WESTERN TERRITORY, DEL ORO DIVISION SCHEDULE OF FINDINGS AND QUESTIONED COSTS SEPTEMBER 30, 2022 Reference Number: 2022-001 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: State of California- Department of Housing and Community Development Federal Program: Emergency Solutions Grant Program ALN Number: 14.231 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness, Noncompliance Criteria or specific requirement: As per ? 200.318 General procurement standards. (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. (b) Non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. (d) The Non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Based on our review of the Procurement compliance requirements, we noted that the Division has written procurement policies and competitive policies as required by CFR ? 200.318 General procurement standards. We selected two (2) vendors for procurement Suspension and Debarment compliance testing of total population of 2 vendors subject to procurement and we were not provided with Procurement comparative bids therefore, we were unable: ? To verify that the procurement method used was appropriate based on the dollar amount and conditions specified in 2 CFR section 200.320. ? To Verify that procurements provide full and open competition (2 CFR section 200.319 and 48 CFR section 52.244-5). Cause: The Division did not ensured that as a non-Federal entity must have and must use documented procurement procedures, consistent with State, and local laws and regulations and the standards of ?? 200.318 through 200.327, for the acquisition of property or services required under a Federal award or subaward. Effect: The funding agency can reject the expenditures incurred by the Division on certain vendors where the Division must use procurement method appropriately based on the dollar amount and conditions specified in 2 CFR section 200.320. Questioned costs: Cannot be determined Recommendation: We recommend that the Division must: (1) document procurement procedures, consistent with State, and local, laws and regulations and the standards, for the acquisition of property or services required under a federal award or subaward. (2) The Division?s documented procurement procedures must conform to the procurement standards identified in ?? 200.318 through 200.327. Views of responsible officials: The Division will work with Territorial Headquarters to document procedures as outlined in the Recommendations above. See corrective action plan.
2022-009 – Procurement Documentation Finding Type: Significant Deficiency in Internal Controls and Noncompliance (Procurement, Suspension & Debarment) Federal Program: U.S. Department of Treasury – Coronavirus State and Local Fiscal Recovery Funds (AL #21.027) Criteria: The Code of Federal Regulations (CFR) Section 200.318(a) requires non-Federal entities to establish and use documented procurement procedures that conform to the procurement standards identified in Sections 200.317 through 200.327. Condition: While the County does have a written procurement policy that meets the requirements, the policy was not being followed. The County did not maintain records sufficient to detail the history of procurement including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The County did not maintain documentation to sufficiently support noncompetitive procurement on one contract tested. The County did not maintain written documentation of a cost analysis. County management indicated that many of the items procured were processed through the Michigan MiDeal website, but a contract file was not maintained. Cause: The County does not have controls in place to ensure that its procurement policy is being followed. Effect: As a result of this condition, the County did not fully comply with the Uniform Guidance. Questioned Costs: No costs have been questioned as a result of this finding. Recommendation: We recommend that the County implement controls to ensure the procurement policy is followed. Views of Responsible Officials: The County will work to implement controls to ensure the procurement policy is followed.
Information on the Federal Program: Assistance Listing Number 21.027-Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of the Treasury. Compliance Requirements: Procurement. Type of Finding: Noncompliance. Criteria: 2 CFR § 200.319(d) requires that the non-Federal entity must maintain written procedures for procurement transactions. Condition: We noted that the County did not have written procedures for procurement transactions that include the provisions required by the Procurement Standards 2 CFR § 200.318 through 2 CFR § 200.327 in fiscal year 2022. Cause: The County was not aware of the requirement to have written procedures for procurement transactions. Effect: Failure to have adequate written procedures for procurement transactions could result in the acquisition of goods or services in violation with administrative requirements, federal regulations, other procurement requirements, and Uniform Guidance requirements. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the County identify grants that are subject to Uniform Guidance on a timely basis to ensure all compliance requirements are met and develop adequate written policies and procedures for procurement transactions. Views of Responsible Officials and Planned Corrective Action: The County has identified federal grants subject to the Uniform Guidance and will develop written policies and procedures which include the relevant provisions required by 2 CFR § 200.318 through 2 CFR § 200.326 Contract provisions.
Finding 2022-005 – Procurement Policies Assistance Listing #: ALL Criteria: The Uniform Guidance, 2 CFR Subpart D, requires that all non-federal entities must follow the procurement standards as set forth in parts §200.318 through §200.327 and the non-federal entity’s documented procurement procedures must conform to these procurement standards. Condition: The Organization has general policies and procedures that broadly address procurement, however, the written policies do not comply with the requirements of the Uniform Guidance. The Organization’s procurement policies have been adopted using a model applicable to a commercial entity with multiple references to the Federal Acquisition Regulation (FAR) and its standards, rather than a non-profit organization subject to the Uniform Guidance. Cause: As noted above, fiscal year 2022 is the Organization’s first Single Audit and It appears the Organization is not fully aware of the applicable requirements. Effect: The Organization is not in compliance with the requirements of the Uniform Guidance and its relative procurement standards. In addition, since the Organization is not following the procurement guidance as specified, they are at a heightened risk that they will procure goods and services outside of the allowed scope of the Uniform Guidance, not follow proper procurement steps to selection, and/or not maintain proper procurement history, etc. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend management update its procurement policies and procedures to comply with the requirements of the Uniform Guidance. Response: The Organization is generally identified and approached by Federal agencies, or prime contractors having or considering federal agencies, to utilize grant funding for NFFCMH contracts. The Organization works with trusted partners, each having a unique or specialized forte within the grant requirements, to assemble a joint team of providers. Many of these partners are, due to repeated utilization and unique recognition within their field, uniquely qualified, or the true only option, for their areas of expertise. The Organization will revise the procurement policy to comply with Uniform Guidance, as opposed to the Federal Acquisition Regulations.
Finding 2022-005 – Procurement Policies Assistance Listing #: ALL Criteria: The Uniform Guidance, 2 CFR Subpart D, requires that all non-federal entities must follow the procurement standards as set forth in parts §200.318 through §200.327 and the non-federal entity’s documented procurement procedures must conform to these procurement standards. Condition: The Organization has general policies and procedures that broadly address procurement, however, the written policies do not comply with the requirements of the Uniform Guidance. The Organization’s procurement policies have been adopted using a model applicable to a commercial entity with multiple references to the Federal Acquisition Regulation (FAR) and its standards, rather than a non-profit organization subject to the Uniform Guidance. Cause: As noted above, fiscal year 2022 is the Organization’s first Single Audit and It appears the Organization is not fully aware of the applicable requirements. Effect: The Organization is not in compliance with the requirements of the Uniform Guidance and its relative procurement standards. In addition, since the Organization is not following the procurement guidance as specified, they are at a heightened risk that they will procure goods and services outside of the allowed scope of the Uniform Guidance, not follow proper procurement steps to selection, and/or not maintain proper procurement history, etc. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend management update its procurement policies and procedures to comply with the requirements of the Uniform Guidance. Response: The Organization is generally identified and approached by Federal agencies, or prime contractors having or considering federal agencies, to utilize grant funding for NFFCMH contracts. The Organization works with trusted partners, each having a unique or specialized forte within the grant requirements, to assemble a joint team of providers. Many of these partners are, due to repeated utilization and unique recognition within their field, uniquely qualified, or the true only option, for their areas of expertise. The Organization will revise the procurement policy to comply with Uniform Guidance, as opposed to the Federal Acquisition Regulations.
Finding 2022-005 – Procurement Policies Assistance Listing #: ALL Criteria: The Uniform Guidance, 2 CFR Subpart D, requires that all non-federal entities must follow the procurement standards as set forth in parts §200.318 through §200.327 and the non-federal entity’s documented procurement procedures must conform to these procurement standards. Condition: The Organization has general policies and procedures that broadly address procurement, however, the written policies do not comply with the requirements of the Uniform Guidance. The Organization’s procurement policies have been adopted using a model applicable to a commercial entity with multiple references to the Federal Acquisition Regulation (FAR) and its standards, rather than a non-profit organization subject to the Uniform Guidance. Cause: As noted above, fiscal year 2022 is the Organization’s first Single Audit and It appears the Organization is not fully aware of the applicable requirements. Effect: The Organization is not in compliance with the requirements of the Uniform Guidance and its relative procurement standards. In addition, since the Organization is not following the procurement guidance as specified, they are at a heightened risk that they will procure goods and services outside of the allowed scope of the Uniform Guidance, not follow proper procurement steps to selection, and/or not maintain proper procurement history, etc. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend management update its procurement policies and procedures to comply with the requirements of the Uniform Guidance. Response: The Organization is generally identified and approached by Federal agencies, or prime contractors having or considering federal agencies, to utilize grant funding for NFFCMH contracts. The Organization works with trusted partners, each having a unique or specialized forte within the grant requirements, to assemble a joint team of providers. Many of these partners are, due to repeated utilization and unique recognition within their field, uniquely qualified, or the true only option, for their areas of expertise. The Organization will revise the procurement policy to comply with Uniform Guidance, as opposed to the Federal Acquisition Regulations.
Finding 2022-005 – Procurement Policies Assistance Listing #: ALL Criteria: The Uniform Guidance, 2 CFR Subpart D, requires that all non-federal entities must follow the procurement standards as set forth in parts §200.318 through §200.327 and the non-federal entity’s documented procurement procedures must conform to these procurement standards. Condition: The Organization has general policies and procedures that broadly address procurement, however, the written policies do not comply with the requirements of the Uniform Guidance. The Organization’s procurement policies have been adopted using a model applicable to a commercial entity with multiple references to the Federal Acquisition Regulation (FAR) and its standards, rather than a non-profit organization subject to the Uniform Guidance. Cause: As noted above, fiscal year 2022 is the Organization’s first Single Audit and It appears the Organization is not fully aware of the applicable requirements. Effect: The Organization is not in compliance with the requirements of the Uniform Guidance and its relative procurement standards. In addition, since the Organization is not following the procurement guidance as specified, they are at a heightened risk that they will procure goods and services outside of the allowed scope of the Uniform Guidance, not follow proper procurement steps to selection, and/or not maintain proper procurement history, etc. Questioned Costs: N/A Repeat Finding: No Recommendation: We recommend management update its procurement policies and procedures to comply with the requirements of the Uniform Guidance. Response: The Organization is generally identified and approached by Federal agencies, or prime contractors having or considering federal agencies, to utilize grant funding for NFFCMH contracts. The Organization works with trusted partners, each having a unique or specialized forte within the grant requirements, to assemble a joint team of providers. Many of these partners are, due to repeated utilization and unique recognition within their field, uniquely qualified, or the true only option, for their areas of expertise. The Organization will revise the procurement policy to comply with Uniform Guidance, as opposed to the Federal Acquisition Regulations.
2022-003—Procurement, Suspension and Debarment Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.318, a non-federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. The entity's documented procurement procedures must conform to the procurement standards identified in Parts 200.317 through 200.327, including written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition: The Institute has not developed and approved policies and procedures over procurement, suspension and debarment as required by the Uniform Guidance. Questioned Costs: None. Context: N/A Cause: The Institute had never been subject to an external audit prior to 2021 and had not developed formal policies and procedures over procurement, among others. Effect: The Institute is not in compliance with the Uniform Guidance general procurement standards at 2 CFR Part 200.318. Auditor’s Recommendations: The Institute should development written policies and procedures over procurement, suspension and debarment that meets the requirements of 2 CFR Parts 200.317 through 200.327. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-003—Procurement, Suspension and Debarment Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.318, a non-federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. The entity's documented procurement procedures must conform to the procurement standards identified in Parts 200.317 through 200.327, including written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition: The Institute has not developed and approved policies and procedures over procurement, suspension and debarment as required by the Uniform Guidance. Questioned Costs: None. Context: N/A Cause: The Institute had never been subject to an external audit prior to 2021 and had not developed formal policies and procedures over procurement, among others. Effect: The Institute is not in compliance with the Uniform Guidance general procurement standards at 2 CFR Part 200.318. Auditor’s Recommendations: The Institute should development written policies and procedures over procurement, suspension and debarment that meets the requirements of 2 CFR Parts 200.317 through 200.327. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-003—Procurement, Suspension and Debarment Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.318, a non-federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. The entity's documented procurement procedures must conform to the procurement standards identified in Parts 200.317 through 200.327, including written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition: The Institute has not developed and approved policies and procedures over procurement, suspension and debarment as required by the Uniform Guidance. Questioned Costs: None. Context: N/A Cause: The Institute had never been subject to an external audit prior to 2021 and had not developed formal policies and procedures over procurement, among others. Effect: The Institute is not in compliance with the Uniform Guidance general procurement standards at 2 CFR Part 200.318. Auditor’s Recommendations: The Institute should development written policies and procedures over procurement, suspension and debarment that meets the requirements of 2 CFR Parts 200.317 through 200.327. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-003—Procurement, Suspension and Debarment Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.318, a non-federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. The entity's documented procurement procedures must conform to the procurement standards identified in Parts 200.317 through 200.327, including written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition: The Institute has not developed and approved policies and procedures over procurement, suspension and debarment as required by the Uniform Guidance. Questioned Costs: None. Context: N/A Cause: The Institute had never been subject to an external audit prior to 2021 and had not developed formal policies and procedures over procurement, among others. Effect: The Institute is not in compliance with the Uniform Guidance general procurement standards at 2 CFR Part 200.318. Auditor’s Recommendations: The Institute should development written policies and procedures over procurement, suspension and debarment that meets the requirements of 2 CFR Parts 200.317 through 200.327. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-003—Procurement, Suspension and Debarment Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.318, a non-federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. The entity's documented procurement procedures must conform to the procurement standards identified in Parts 200.317 through 200.327, including written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition: The Institute has not developed and approved policies and procedures over procurement, suspension and debarment as required by the Uniform Guidance. Questioned Costs: None. Context: N/A Cause: The Institute had never been subject to an external audit prior to 2021 and had not developed formal policies and procedures over procurement, among others. Effect: The Institute is not in compliance with the Uniform Guidance general procurement standards at 2 CFR Part 200.318. Auditor’s Recommendations: The Institute should development written policies and procedures over procurement, suspension and debarment that meets the requirements of 2 CFR Parts 200.317 through 200.327. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
2022-003—Procurement, Suspension and Debarment Federal program information: Funding agency: All Title: All Assistance Listing Number (ALN): All Award year and number: All Pass-through entity (if applicable): All Criteria: According to 2 CFR Part 200.318, a non-federal entity must have and use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. The entity's documented procurement procedures must conform to the procurement standards identified in Parts 200.317 through 200.327, including written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Condition: The Institute has not developed and approved policies and procedures over procurement, suspension and debarment as required by the Uniform Guidance. Questioned Costs: None. Context: N/A Cause: The Institute had never been subject to an external audit prior to 2021 and had not developed formal policies and procedures over procurement, among others. Effect: The Institute is not in compliance with the Uniform Guidance general procurement standards at 2 CFR Part 200.318. Auditor’s Recommendations: The Institute should development written policies and procedures over procurement, suspension and debarment that meets the requirements of 2 CFR Parts 200.317 through 200.327. Management’s Response: Management of the Institute did not provide any comments in response to this finding.
Criteria: A non-federal entity is required to have certain written policies and procedure in compliance with Uniform Guidance and must comply with the procurement standards as described in 2 CFR 200.318 through 2 CFR 200.327. Specifically, the non-federal entity must comply with the following: • The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. • If the non-Federal entity has a parent, affiliate, or subsidiary organization that is not a State, local government, or Indian tribe, the non-Federal entity must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest means that because of relationships with a parent company, affiliate, or subsidiary organization, the non-Federal entity is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. Condition: AIRS does not appear to have created written purchasing or procurement policies and procedures as required by 2 CFR 200.318(a). Since AIRS is an affiliate organization of the Ethiopian Community Development Council (ECDC), it appears that the relationship between AIRS and ECDC meets the “affiliate” requirement under 2 CFR 200.318 (c) (2). It does appear that AIRS has created written standards of conduct covering organizational conflicts of interest. Cause: Management has not created or maintained certain written policies and procedures as required under 2 CFR 200.318. Effect: AIRS is not in compliance with certain written policies and procedures as required under 2 CFR 200.318. Questioned Costs: None reported Repeat Finding from Prior Year: Yes Recommendation: In response to Finding 2021-006 during the audit for the year ended September 30, 2021, management has started the process of creating, updating and revising its written policies and procedures. I commend management for their efforts. However, I strongly recommend that management and board complete the written procurement policies and procedures and written standards of conduct covering organizational conflicts of interest prior to start of the 2023 audit. Views of Responsible Officials: Management concurs with this audit finding.
Assistance Listing Number, Federal Agency, and Program Name - 21.027 U.S. Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number and Year - YDYNCVFA9NH4 Pass through Entity - City of Raleigh, North Carolina Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - 2 CFR 200.318 requires that a nonfederal entity that acquires property or services under a federal award or subaward is required to adopt, maintain, and follow written procurement procedures, which comply with sections 2 CFR 200.318 through 327. Condition - WakeMed does not have a written policy in place over procurement methods, which covers 2 CFR 200.318 200.327, nor did WakeMed follow required procurement guidelines. Questioned Costs - $1,010,233 Identification of How Questioned Costs Were Computed - Questioned costs reflect the entire amount of costs expended under the grant during 2022. Context - WakeMed did not have a written policy in place over procurement methods, which covers 2 CFR 200.318 200.327, when the grant was awarded. In addition, WakeMed did not follow required procurement procedures related to expenditures under the grant, including a competitive bid process for costs charged to the grant as WakeMed entered into the construction contract prior to being awarded the funds. Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including procurement provisions, where controls were not in place to identify the requirement to have a written procurement policy and follow 2 CFR 200.318 200.327. Recommendation - WakeMed should develop a written procurement policy, which complies with the 2 CFR 200.318 200.327 sections, and ensure controls are in place to comply with the procurement policy on an ongoing basis. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding as reported. WakeMed is in the process of updating their existing procurement policy to include the relevant sections from the Code of Federal Regulations and will provide education to the areas involved in procurement and use of federal funds on these requirements.