Finding 1168300 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-07

AI Summary

  • Core Issue: Significant deficiency in procurement practices identified during testing of expenditures.
  • Impacted Requirements: Nonprofits must follow Uniform Guidance and Texas Grant Management Standards for procurement, including maintaining detailed records.
  • Recommended Follow-Up: Reinforce adherence to procurement policies and ensure proper documentation is maintained to avoid unnecessary costs.

Finding Text

Finding #2025-001 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Assistance Listing #14.218, Passed through Harris County, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #’s: C2023-006G, C2024-006H, and C2020-050G, Contract years: 10/23-09/24, 10/24-09/25, and 03/24-09/24. Assistance Listing #14.218, Passed through City of Houston, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #: 4600016648, Contract year: 05/25-06/25. U. S. Department of Health and Human Services, Assistance Listing #93.576, Passed through Episcopal Migration Ministries, Refugee and Entrant Assistance Discretionary Grants, Contract #’s: 90RP0117‐01-00, 90RP0117-02-00, 90RP0117-03-00, and 90RP0117-04-00, Contract years: 10/23-09/24 and 10/24-09/25. Applicable state program: Texas Department of Agriculture, Home-Delivered Meal Grant Program, Contract #’s: HDM2024029-070-071 and HDM2025052-053, Contract years: 02/24-01/25 and 02/25-01/26. Criteria: Procurement – Nonprofit organizations are required to adopt policies in accordance with the Uniform Guidance §200.318 and the Texas Grant Management Standards. Additionally, nonprofit organizations must maintain records sufficient to detail the history of procurement including the rationale for the procurement method, vendor selection or rejection, and the basis for the contracted price. Condition and context: During our testing of 24 expenditures requiring procurement, we identified one instance of expenditures in Home-Delivered Meal Grant Program greater than the simplified acquisition threshold of $10,000 where simplified acquisition procedures in accordance with Interfaith Ministries’ policy were not followed. Cause: The finding occurred due to failure to follow established procurement policies and procedures. Effect: Failure to follow procurement procedures may result in Interfaith Ministries purchasing goods or services for more than would be necessary if required procurement procedures had been followed. Recommendation: Emphasize adherence to established policies and procedures to ensure procurement is performed according to the procurement policy, and that proper procurement documentation is maintained. Views of responsible officials and planned corrective actions: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Finding #2025-001 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Assistance Listing #14.218, Passed through Harris County, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #’s: C2023-006G, C2024-006H, and C2020-050G, Contract years: 10/23-09/24, 10/24-09/25, and 03/24-09/24. Assistance Listing #14.218, Passed through City of Houston, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #: 4600016648, Contract year: 05/25-06/25. U. S. Department of Health and Human Services, Assistance Listing #93.576, Passed through Episcopal Migration Ministries, Refugee and Entrant Assistance Discretionary Grants, Contract #’s: 90RP0117‐01-00, 90RP0117-02-00, 90RP0117-03-00, and 90RP0117-04-00, Contract years: 10/23-09/24 and 10/24-09/25. Applicable state program: Texas Department of Agriculture, Home-Delivered Meal Grant Program, Contract #’s: HDM2024029-070-071 and HDM2025052-053, Contract years: 02/24-01/25 and 02/25-01/26. Condition and context: During our testing of 24 expenditures requiring procurement, we identified one instance of expenditures in Home-Delivered Meal Grant Program greater than the simplified acquisition threshold of $10,000 where simplified acquisition procedures in accordance with Interfaith Ministries’ policy were not followed. Recommendation: Emphasize adherence to established policies and procedures to ensure procurement is performed according to the procurement policy, and that proper procurement documentation is maintained. Planned corrective action: Our organization implemented a robust procurement policy effective July 1, 2018 that complies with the guidelines of 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Procurement Standards 200.317-326 and the Texas Grants Management Standards. Under the established procurement method for small purchases between $10,000 and $100,000, Interfaith Ministries is required to obtain price or rate quotations from a minimum of three sources. The management team will re-emphasize the established policy and procedures for procurement with Interfaith Ministries staff. Responsible officer: Sheroo Mukhtiar, Chief Executive Officer and Stephanie Alvarez, Chief Financial Officer. Estimated completion date: December 1, 2025

Categories

Procurement, Suspension & Debarment HUD Housing Programs Significant Deficiency

Other Findings in this Audit

  • 1168295 2025-001
    Material Weakness Repeat
  • 1168296 2025-001
    Material Weakness Repeat
  • 1168297 2025-001
    Material Weakness Repeat
  • 1168298 2025-002
    Material Weakness Repeat
  • 1168299 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.510 U.S. REFUGEE ADMISSIONS PROGRAM $3.08M
93.576 REFUGEE AND ENTRANT ASSISTANCE DISCRETIONARY GRANTS $2.47M
93.567 REFUGEE AND ENTRANT ASSISTANCE VOLUNTARY AGENCY PROGRAMS $1.57M
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $1.56M
93.667 SOCIAL SERVICES BLOCK GRANT $642,583
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $594,197
94.006 AMERICORPS STATE AND NATIONAL 94.006 $287,670
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $247,580
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $163,602
97.067 HOMELAND SECURITY GRANT PROGRAM $24,000