Finding 1159689 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-10-01
Audit: 370280
Organization: The Family Conservancy, INC (KS)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The Agency failed to verify that a vendor receiving over $25,000 in federal funds was not suspended or debarred, violating Uniform Guidance requirements.
  • Impacted Requirements: Lack of documentation and controls means the Agency is non-compliant with suspension and debarment regulations, risking unallowable costs and potential loss of federal funding.
  • Recommended Follow-Up: Implement procedures to verify vendor status and maintain documentation for all contracts and purchases exceeding $25,000.

Finding Text

Finding 2024-002: Procurement, suspension and debarment Federal award agency: U.S. Department of Treasury Pass-through granting agency: Unified Government of Wyandotte County, Kansas and Kansas City, Kansas Program name and ALN: Coronavirus State and Local Fiscal Recovery Funds, 21.027 (COVID-19) Federal award identification number: SLFRP3214 Federal award year: November 17, 2022 to December 31, 2024 Criteria: The Uniform Guidance stipulates that when a nonfederal entity enters into a contract or purchase with a vendor that is equal to or exceeds $25,000, the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants. Condition: During testing, we identified one vendor that these procedures were not performed for. As such, the Agency's controls were not operating effectively to support the Agency had verified suspension and debarment as no documentation is maintained that can provide evidence that the Agency had verified this entity, which received $25,000 or more in federal grant funds, was not suspended or debarred prior to providing them with federal funds. Cause: A lack of maintaining documentation, as well as controls that could support this verification had been performed. Effect or potential effect: The Agency is not in compliance with suspension and debarment requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None. Context: During testing, we identified one vendor that these procedures were not performed for. As such, the Agency's controls were not operating effectively to support the Agency had verified suspension and debarment as no documentation is maintained that can provide evidence that the Agency had verified this entity, which received $25,000 or more in federal grant funds, was not suspended or debarred prior to providing them with federal funds. Repeat finding: No. Recommendation: We recommend that the Agency establish controls and personnel establish and follow procedures to determine whether vendors have been suspended and debarred prior to entering into contracts or purchase orders for all transactions and maintaining documentation supporting this verification. Views of responsible officials: Management agrees with this finding. See corrective action plan.

Corrective Action Plan

Corrective Action Plan Identifying Number: 2024-002 Finding: The Agency did not verify that one particular vendor was not suspended or debarred when it entered into a contract with the vendor who received $25,000 or more in federal grant funds. Corrective Actions Taken or Planned: 1. Review of Vendor Requirement Checks a formal review will be implement to review the procurement contract reviews and verification performed prior to any expenditures related to the contract are performed. 2. Training and Vendor Requirement Checks- Provide training to all procurement staff on federal grant compliance requirements, including performance and documentation of the suspension/debarment verification via SAM.gov prior to entering into a contract. 3. Ongoing Monitoring – The VP of Finance will provide updates to senior leadership and the Finance Committee. Contact Person Responsible for Corrective Action: Gino Taylor, Vice President of People, Culture, & Equity Fred Timberlake, Vice President of Finance Isha Martin, Controller/Grant Finance Manager Anticipated Completion Date: ● Written procedures in place: September 30, 2025 ● Staff training completed: October 31, 2025 ● Audit completion: December 31, 2025

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1159688 2024-001
    Material Weakness Repeat
  • 1159690 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.600 Head Start $2.17M
21.027 Covid-19: Coronavirus State and Local Fiscal Recovery Funds $1.28M
10.558 Child and Adult Care Food Program $996,658
93.575 Child Care and Development Block Grant $45,827
93.590 Community-Based Child Abuse Prevention Grants $35,087
16.575 Crime Victim Assistance $21,738