Finding 1150501 (2024-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-20
Audit: 364634
Organization: Easter Seals Serving Dc/md/va (MD)
Auditor: Aprio LLP

AI Summary

  • Core Issue: A procurement contract was signed by someone without the necessary authority, violating internal controls.
  • Impacted Requirements: This noncompliance breaches 2 CFR 200.318(a) and the Organization’s own procurement policy, risking unauthorized spending.
  • Recommended Follow-Up: Ensure training and oversight are improved to enforce procurement policies and prevent future issues.

Finding Text

Finding 2024-004: Reportable finding considered a significant deficiency - Noncompliance with Internal Procurement Authorization Controls Program name: Child and Adult Care Food Program Assistance Listing: 10.558 Federal awarding agency: U.S. Department of Agriculture (USDA) Pass-through Entity: Maryland State Department of Education, District of Columbia Education Office Criteria: Under 2 CFR 200.318(a), non-federal entities must establish and maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. As required under 2 CFR Subpart D (§§200.317–200.327), organizations must follow written procurement procedures that reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards in the Uniform Guidance. The Organization’s internal procurement policy includes specific thresholds for contract approvals and designates levels of review and signature authority based on the contract value. Adherence to these internal controls is essential to ensure compliance with federal procurement requirements and appropriate stewardship of federal funds. Condition: During our testing of procurement activity, we noted that a procurement contract was executed by an individual who did not have the delegated authority to approve or sign the agreement, as required by the Organization’s internal procurement policy. The contract amount exceeded the individual’s approval threshold. The policy’s required internal approval levels were not followed prior to execution. Cause: This issue appears to have resulted from a breakdown in adherence to established internal control procedures, possibly due to a lack of training or oversight. The Organization’s procurement policy was in place and compliant with 2 CFR requirements, but it was not enforced in practice. Effect: Noncompliance with internal procurement approval controls increases the risk of unauthorized or inappropriate spending, lack of transparency, and potential ineligibility of costs charged to federal programs. While the transaction itself may ultimately be allowable, failure to follow established approval protocols constitutes a significant deficiency in internal control over compliance. Repeat finding: This is not a repeat finding. Questioned costs: None identified, as the expenditure appeared otherwise allowable. However, the control deficiency presents a risk for future noncompliance. Perspective: We selected two procurement transactions from a population of four procurement transactions from this program. The issue reflects a control failure affecting procurement activity across federally funded programs and may result in future questioned costs if not corrected. Recommendation: We recommend that the Organization follow up with the relevant parties to ensure proper reporting requirements are met on a timely basis. Management’s response and corrective action plan (unaudited): See corrective action plan.

Categories

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility Reporting Significant Deficiency

Other Findings in this Audit

  • 574052 2024-003
    Significant Deficiency
  • 574053 2024-004
    Significant Deficiency
  • 574054 2024-005
    Significant Deficiency
  • 574055 2024-005
    Significant Deficiency
  • 574056 2024-005
    Significant Deficiency
  • 574057 2024-005
    Significant Deficiency
  • 574058 2024-003
    Significant Deficiency
  • 574059 2024-004
    Significant Deficiency
  • 574060 2024-005
    Significant Deficiency
  • 1150494 2024-003
    Significant Deficiency
  • 1150495 2024-004
    Significant Deficiency
  • 1150496 2024-005
    Significant Deficiency
  • 1150497 2024-005
    Significant Deficiency
  • 1150498 2024-005
    Significant Deficiency
  • 1150499 2024-005
    Significant Deficiency
  • 1150500 2024-003
    Significant Deficiency
  • 1150502 2024-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
17.805 Homeless Veterans’ Reintegration Program $790,278
10.558 Child and Adult Care Food Program $319,493
93.493 Congressional Directives $275,526
93.600 Head Start $234,838
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $97,358
93.575 Child Care and Development Block Grant $50,000
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $45,059
21.027 Coronavirus State and Local Fiscal Recovery Funds $15,000
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $10,824
14.218 Community Development Block Grants/entitlement Grants $0