Finding 1138337 (2024-004)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-05-29
Audit: 357546
Organization: US Water Alliance (WA)

AI Summary

  • Core Issue: The Alliance failed to keep necessary documentation for checking if subrecipients were suspended or debarred before issuing subawards.
  • Impacted Requirements: This oversight means the Alliance is not fully compliant with 2 CFR Section 200.214 and related guidelines on subrecipient monitoring.
  • Recommended Follow-Up: The Alliance should enhance its processes to ensure all required documentation for suspension and debarment checks is properly retained and accessible.

Finding Text

Criteria: Per 2 CFR Section 200.214 and Appendix II to Part 200, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify that a subrecipient is not suspended or debarred at the time of the award, either by checking the SAM.gov exclusion list, collecting a certification or including appropriate contract clauses. Condition and context: During testing of the Alliance’s controls on compliance over subrecipient monitoring and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check prior to making a subaward. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check prior to issuing subawards. Effect: The Alliance was not fully in compliance with the subrecipient monitoring and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over subrecipient monitoring and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 561892 2024-001
    Significant Deficiency
  • 561893 2024-002
    Significant Deficiency
  • 561894 2024-003
    Significant Deficiency
  • 561895 2024-004
    Significant Deficiency
  • 1138334 2024-001
    Significant Deficiency
  • 1138335 2024-002
    Significant Deficiency
  • 1138336 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
66.203 Environmental Finance Center Grants $11,655