Finding 1157034 (2024-002)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2024

Accepted

2025-09-30

Audit: 369350

Organization: Our Katahdin and Subsidiary (ME)

Auditor: Bdmp Assurance LLP

AI Summary

Core Issue: The Organization failed to verify that its vendors were not suspended or debarred from federal funding.
Impacted Requirements: Compliance with 2 CFR §180.300 is necessary for all covered transactions involving lower-tier entities.
Recommended Follow-Up: Update policies to ensure all vendors are checked against the Excluded Parties List System before engaging in transactions.

Finding Text

Program Affected 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2023 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria 2 CFR §180.300 mandates that 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 is not suspended or debarred or otherwise excluded from participating in the transaction. Condition and Context The Organization did not perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 6 of 6 vendors tested were not verified against the Excluded Parties List System. Cause and Effect The Organization does not have internal processes to properly identify excluded parties ineligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties. Questioned Costs N/A Identification of Repeat Findings 2023-009 Recommendation We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.

Corrective Action Plan

The Organization will verify all current active vendors against the SAM.gov exclusions database, document verification results, and remediate any issues identified. Going forward, the Organization will modify its policy to establish quarterly vendor verification review by the management team. The Organization will conduct a quarterly review of vendor verification documentation by reviewing the accounting system vendor list against the SAM.gov exclusion search documentation to help ensure no vendors were omitted, verifying that the date of each SAM.gov search is properly documented, and documenting the management team’s review findings and any corrective actions taken. Person Responsible: Stephanie Walsh, Treasurer, Tel: 207-249-8578 Estimated completion: December 2025

Other Findings in this Audit

1157030 2024-002

Material Weakness Repeat
1157031 2024-002

Material Weakness Repeat
1157032 2024-002

Material Weakness Repeat
1157033 2024-002

Material Weakness Repeat
1157035 2024-003

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
11.307	Economic Adjustment Assistance	$3.66M
14.251	Economic Development Initiative, Community Project Funding, and Miscellaneous Grants	$671,000
66.818	Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements	$157,815