Finding 1150903 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-08-22
Audit: 364795
Organization: Intertribal Agriculture Council (MS)

AI Summary

  • Core Issue: The Organization failed to verify subcontractors' eligibility, risking payments to excluded parties.
  • Impacted Requirements: Noncompliance with 2 CFR §200.214 and 2 CFR Part 180 regarding suspension and debarment checks.
  • Recommended Follow-Up: Establish and document procedures to verify subcontractor eligibility for all transactions over $25,000.

Finding Text

Criteria: According to 2 CFR §200.214, nonfederal entities other than states must follow the suspension and debarment standards set out at 2 CFR Part 180, which restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition: During our audit of the Organization's federal awards, we identified a deficiency in the grantee’s procurement, suspension, and debarment procedures related to suspension and debarment for 4 of 4 subcontractors we reviewed. Specifically, the grantee did not verify that subcontractors were not excluded or disqualified before entering into transactions expected to exceed $25,000 in accordance with the Uniform Guidance. Cause: The Organization did not have adequate policies and procedures or internal controls in place to ensure compliance with the procurement, suspension, and debarment requirements. Effect: The Organization may be paying subcontractors that are suspended or debarred, which would be unallowable costs. However, none of the 4 subcontractors were suspended or debarred as of the date audit procedures were performed. Recommendation: We recommend that the Organization implement policies and procedures to ensure that all subcontractors and subrecipients of covered transactions are properly verified before entering into transactions, and that this be documented as a control each time it is performed. Views of Responsible Officials: Management agrees with the finding and procedures have been implemented to address the related issues.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 574458 2024-001
    Significant Deficiency
  • 574459 2024-002
    Significant Deficiency
  • 574460 2024-001
    Significant Deficiency
  • 574461 2024-002
    Significant Deficiency
  • 1150900 2024-001
    Significant Deficiency
  • 1150901 2024-002
    Significant Deficiency
  • 1150902 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.234 American Rescue Plan Technical Assistance Investment Program $2.43M
10.186 Regional Food Business Centers $1.61M
10.184 Pandemic Relief Activities: Meat and Poultry Processing Capacity - Technical Assistance Grants $914,651
10.601 Market Access Program $627,472
10.460 Risk Management Education Partnerships $444,897
10.968 Increasing Land, Capital, and Market Access Program $392,555
10.069 Conservation Reserve Program $382,563
10.048 Tribal Agriculture Technical Assistance $316,440
10.U01 Intertribal Agriculture Council American Indian Foods Program Domestic Market Ffy 2023 $110,698
10.975 Emergency Relief Program Outreach Education and Technical Assistance $104,649
10.618 Regional Agricultural Promotion Program $100,285
10.531 State Agency: Farm to School Program Training and Curricula $76,345
10.U02 Otr Native Youth (nyta 23-24) $60,338
93.103 Food and Drug Administration Research $44,866
10.147 Outreach Education and Technical Assistance $40,584
10.937 Partnerships for Climate-Smart Commodities $19,470
10.902 Soil and Water Conservation $14,876
10.912 Environmental Quality Incentives Program $9,218