Finding Text
Federal Agency: U.S. Department of Health & Human Services
Federal Program Name: Refugee and Entrant Assistance Voluntary Agency Programs
Assistance Listing Number: 93.576
Federal Award Identification Number and Year: Various, see below
Pass-Through Agency: Various, see below
Pass-Through Number: Various, see below
Award Period: Various, see below
Compliance Requirement Affected: Suspension & Debarment
Direct Agency Direct Award number Award Period
Pass Through Entity (or) Pass Through Number
U.S. Department of
Health & Human Services (Direct) 90RG0243-01-00 10/1/2023-9/30/2024
90RG0225-01-00 10/1/2022-9/29/2025
90ZI0174-01-00 9/30/2023-09/29/2027
Passed through California
Department of Social Services N/A 10/1/2023-9/30/2024
Passed through Los Rios
Community College District N/A 9/30/2022-9/29/2025
Passed through Church World
Services CWS-2024-04-015 10/1/2023-9/30/2024
CWS-2024-10-017 10/1/2024-9/30/2025
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: 2 CFR 200.403(a) - When a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and
agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in
the transaction.
Condition: During our single audit procedures, 100% of our suspension and debarment samples selected did not
contain sufficient documentation detailing the Organization’s process for determining the vendor was
not suspended nor debarred prior to participating in the transaction.
Context: A nonstatistical sample of 6 out of 21 vendors were selected for testing for the Refugee and Entrant
Assistance Voluntary Agency Programs program. The condition noted above was identified during our
procedures over ODI's Suspension and Debarment.
Effect: ODI did not verify suspension or debarment status, which could result in entering into a contract with a
vendor, which is potentially suspended or debarred.
Cause: ODI did not consistently ensure that Suspension or Debarment status was verified before entering into
agreements with the vendors.
Repeat Finding: The finding is not a repeat finding.
Recommendation: We recommend that ODI strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for vendors subject to verification according to ODI's Procurement policy, prior to entering into a contract with the vendor.
Management’s Views: Management notes that debarment checks performed post transactions confirmed that no vendors were suspended or debarred. Management takes responsibility for the finding and believes that in
future years, they will be able to implement proper controls to mitigate this finding.