Finding Text
Findings and Questioned Costs - Major Federal Programs Audit
Finding No. 2023-002
Name of Federal Agency: U.S Department of Treasury
Federal Program Name: Corona Virus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: Identification number unavailable. Program year 2023
Name of Pass-through Entity (if applicable): The Community Economic Development Assistance Corporation
Criteria: In accordance with §200.318(a), General Procurement Standards, a non-federal entity must use its own
documented procurement procedures which reflect applicable State, local, and tribal laws and regulations,
provided that the procurements conform to applicable federal law and the standards identified in General
Procurement Standards. Additionally, §200.318(i) states that the non-federal entity must maintain records
sufficient to detail the history of the procurement.
In addition, in accordance with §200.213 and §180.300, non-federal entities cannot enter into awards,
subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or
ineligible for participation in federal assistance programs or activities.
Condition/Context: For 2 procurement samples out of a total of 2 tested, management did not provide adequate
supporting documentation for the procurement including ensuring proper suspension and debarment checks
were performed.
Cause: The Agency did not have adequate policies, procedures, and controls in place to ensure compliance with
the general procurement standards and suspension and debarment requirements.
Effect or Potential Effect: Failure to perform procurement procedures in accordance with a written policy that
complies with the Uniform Guidance could result in the procurement being disallowed. Failure to timely verify
that a vendor is not suspended or debarred could result in entering into a contract with an entity that is barred
from performing work for the U.S. government.
Questioned Costs: None
Identification as a Repeat Finding: This is not a repeat finding
Recommendation: We recommend that the Agency establish written procurement policies and procedures to
ensure that the Agency is in compliance with the Uniform Guidance and that all staff are trained on this policy to
ensure compliance and related internal controls over compliance are operating effectively.
Views of responsible officials: Management agrees with the finding and is in the process of revising internal
controls to address procurement, suspension and debarment requirements. Additionally, management has
retroactively performed this requirement to the applicable transactions during the audit period, noting no vendors
were suspended or debarred.