Finding 1168674 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-09

AI Summary

  • Core Issue: The organization failed to document checks confirming that vendors were not suspended or debarred before engaging in significant contracts.
  • Impacted Requirements: This violates federal regulations (2 CFR Part 180.220) regarding compliance with suspension and debarment rules for federal funding.
  • Recommended Follow-up: Establish a robust internal control system to ensure documentation of vendor status checks and consider obtaining vendor certifications to confirm compliance.

Finding Text

2025-001 Suspension and Debarment Federal agency: U.S. Department of Health and Human Services Federal program title: Maternal, Infant and Early Childhood Home Visiting Grant Program Congressional Directives Grant Program Assistance Listing Numbers: 93.870/93.493 Award Period: July 1, 2024 – June 30, 2026 September 30, 2023 – September 29, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 180.220, states that recipients of federal funds are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded that are expected to equal or exceed $25,000 or meet certain other criteria. Condition: The Village for Families & Children, Inc. and Subsidiaries did not retain documented support of their review of the System for Award Management website demonstrating that they confirmed a vendor was not suspended or debarred prior to entering a covered transaction arrangement with them. Questioned costs: None. Cause: The internal control framework does not mandate that employees maintain documentation of the procedures used to verify a vendor’s suspension or debarment status before entering into a covered transaction. Effect: Noncompliance with the federal award programs’ suspension and debarment compliance requirements could occur and not be detected and corrected timely. Repeat Finding: No Recommendation: Develop and implement an internal control framework that ensures retention of evidence documenting the procedures performed to verify that vendors are not suspended, debarred, or otherwise excluded from conducting business before The Village for Families & Children, Inc. and Subsidiaries procuring their services. Program management should either obtain certifications from applicable vendors or maintain sufficient documentation of their review of the System for Award Management (SAM) website. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Health and Human Services Maternal, Infant and Early Childhood Home Visiting Grant Program – Assistance Listing No. 93.870 Congressional Directives Grant Program – Assistance Listing No. 93.493 Recommendation: Develop and implement an internal control framework that ensures retention of evidence documenting the procedures performed to verify that vendors are not suspended, debarred, or otherwise excluded from conducting business before The Village for Families & Children, Inc. and Subsidiaries procuring their services. Program management should either obtain certifications from applicable vendors or maintain sufficient documentation of their review of the System for Award Management (SAM) website. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Village will establish a standardized process to retain proof of its suspension and debarment review. Compliance with the debarment regulations will be achieved by one of the following methods: 1.) Capturing a screenshot of the verification performed on the System of Award Management (SAM) Exclusions database at SAM.gov, 2.) Obtaining a certification from the entity, or 3.) Including a clause or condition in the agreement related to the covered transaction. The compliance requirements and procedures will be communicated to both Leadership and Finance teams. All supporting documentation will be retained either within the Finance Department or in the respective program records. Name(s) of the contact person(s) responsible for corrective action: Marjorie Loring Planned completion date for corrective action plan: January 31, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1168671 2025-001
    Material Weakness Repeat
  • 1168672 2025-001
    Material Weakness Repeat
  • 1168673 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.493 CONGRESSIONAL DIRECTIVES $1.06M
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $1.01M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $861,172
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $619,000
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $465,039
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $270,305
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $131,763
21.009 VOLUNTEER INCOME TAX ASSISTANCE (VITA) MATCHING GRANT PROGRAM $93,850
93.137 COMMUNITY PROGRAMS TO IMPROVE MINORITY HEALTH $92,216
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $90,025
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $75,000
59.059 CONGRESSIONAL GRANTS $75,000
93.643 CHILDREN'S JUSTICE GRANTS TO STATES $56,159
84.425 EDUCATION STABILIZATION FUND $50,000
93.788 OPIOID STR $50,000
93.600 HEAD START $28,481
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $25,000
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $23,778
10.558 CHILD AND ADULT CARE FOOD PROGRAM $15,052
93.667 SOCIAL SERVICES BLOCK GRANT $7,932
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $6,320