FAC Explorer

Finding 1080504 (2022-007)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-10-29
Audit: 326473
Organization: Unified Government of Wyandotte County and Kansas City, Kansas (KS)
Auditor: Forvis Mazars

AI Summary

  • Core Issue: Suspension and debarment checks were not performed for subrecipients receiving federal funds, risking payments to ineligible entities.
  • Impacted Requirements: Non-compliance with 2 CFR 200.214 and 2 CFR 200.303 regarding internal controls and covered transactions.
  • Recommended Follow-Up: Update policies to ensure suspension and debarment checks are mandatory for all vendors and subrecipients before federal fund disbursement.

Finding Text

U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipients that received federal funds. Questioned Costs: None noted. Context: The single subrecipient under both ALN 93.044 and 93.045 receiving approximately $418,000 was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2021-005 Effect: Federal funds could be paid to entities that are suspended or debarred. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Procurement has begun the process of checking SAM.gov for debarment for potential suppliers. Also, departments have been informed of this required step for both suppliers and subrecipients. Downstream, need to evaluate if this language can be added to the contract templates.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 504061 2022-007
    Significant Deficiency Repeat
  • 504062 2022-007
    Significant Deficiency Repeat
  • 504063 2022-007
    Significant Deficiency Repeat
  • 504064 2022-008
    Material Weakness Repeat
  • 504065 2022-008
    Material Weakness Repeat
  • 504066 2022-008
    Material Weakness Repeat
  • 504067 2022-009
    Significant Deficiency
  • 504068 2022-010
    Significant Deficiency
  • 504069 2022-011
    Significant Deficiency Repeat
  • 504070 2022-012
    Significant Deficiency
  • 504071 2022-013
    Material Weakness
  • 504072 2022-014
    Significant Deficiency
  • 504073 2022-015
    Material Weakness
  • 504074 2022-016
    Material Weakness
  • 504075 2022-017
    Material Weakness
  • 504076 2022-017
    Material Weakness
  • 504077 2022-018
    Significant Deficiency
  • 504078 2022-018
    Significant Deficiency
  • 504079 2022-019
    Material Weakness
  • 504080 2022-019
    Material Weakness
  • 1080503 2022-007
    Significant Deficiency Repeat
  • 1080505 2022-007
    Significant Deficiency Repeat
  • 1080506 2022-008
    Material Weakness Repeat
  • 1080507 2022-008
    Material Weakness Repeat
  • 1080508 2022-008
    Material Weakness Repeat
  • 1080509 2022-009
    Significant Deficiency
  • 1080510 2022-010
    Significant Deficiency
  • 1080511 2022-011
    Significant Deficiency Repeat
  • 1080512 2022-012
    Significant Deficiency
  • 1080513 2022-013
    Material Weakness
  • 1080514 2022-014
    Significant Deficiency
  • 1080515 2022-015
    Material Weakness
  • 1080516 2022-016
    Material Weakness
  • 1080517 2022-017
    Material Weakness
  • 1080518 2022-017
    Material Weakness
  • 1080519 2022-018
    Significant Deficiency
  • 1080520 2022-018
    Significant Deficiency
  • 1080521 2022-019
    Material Weakness
  • 1080522 2022-019
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $9.91M
14.218 Community Development Block Grants/entitlement Grants $2.01M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $1.83M
14.231 Covid-19 Emergency Solutions Grant Program $908,883
14.218 Covid-19 Community Development Block Grants/entitlement Grants $878,625
14.239 Home Investment Partnerships Program $749,810
93.667 Social Services Block Grant $596,437
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $502,390
20.600 State and Community Highway Safety $460,147
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $410,089
16.710 Public Safety Partnership and Community Policing Grants $354,783
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $304,090
16.738 Edward Byrne Memorial Justice Assistance Grant Program $280,440
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $263,480
93.053 Nutrition Services Incentive Program $251,323
93.268 Covid-19 Immunization Cooperative Agreements $245,697
14.900 Lead-Based Paint Hazard Control in Privately-Owned Housing $239,876
66.001 Air Pollution Control Program Support $226,310
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $194,740
14.231 Emergency Solutions Grant Program $166,876
93.778 Medical Assistance Program $161,006
93.217 Family Planning_services $147,764
93.052 National Family Caregiver Support, Title Iii, Part E $129,555
93.069 Public Health Emergency Preparedness $103,036
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $99,556
66.808 Solid Waste Management Assistance Grants $95,000
97.042 Emergency Management Performance Grants $90,660
16.588 Violence Against Women Formula Grants $84,822
93.575 Child Care and Development Block Grant $80,219
16.575 Crime Victim Assistance $75,759
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $64,776
16.817 Byrne Criminal Justice Innovation Program $51,726
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $51,023
95.001 High Intensity Drug Trafficking Areas Program $49,391
93.630 Developmental Disabilities Basic Support and Advocacy Grants $48,045
11.307 Economic Adjustment Assistance $42,779
20.507 Covid-19 Federal Transit_formula Grants $40,991
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $38,417
16.746 Capital Case Litigation Initiative $28,172
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $27,512
21.016 Equitable Sharing $18,700
93.268 Immunization Cooperative Agreements $9,414
93.994 Maternal and Child Health Services Block Grant to the States $6,164
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $3,635