Finding 1172859 (2023-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-02-09
Audit: 386255
Organization: Creating Housing Coalition (OR)
Auditor: JONES & ROTH PC

AI Summary

  • Core Issue: The organization lacks written procurement procedures that meet federal guidelines.
  • Impacted Requirements: Compliance with Uniform Guidance 2 CFR §200.318 through §200.326 is not being met.
  • Recommended Follow-Up: Develop and document formal procurement policies that align with the Uniform Guidance requirements.

Finding Text

Finding 2023-003 Federal Program: Coronavirus State and Local Fiscal Recover Funds, AL# 21.027 Type of Finding: Significant deficiency in internal controls over compliance and immaterial non-compliance Compliance Requirement: Procurement Criteria: In accordance with the Uniform Guidance, specifically 2 CFR §200.318, non-federal entities must have documented procurement procedures that conform to the Uniform Guidance 2 CFR §200.318 through §200.326. Condition and Context: The auditee did not have written procurement procedures that conformed to the Uniform Guidance 2 CFR §200.318 through §200.326. However, the auditee did follow the methods of procurement required (per 2 CFR §200.320) for federal procurements made during the audit period. Cause: There were not adequate internal controls over compliance in place to ensure there were written procurement policies that conformed with the Uniform Guidance. Effect: The deficiency in the internal controls over compliance could result in material non-compliance with the procurement compliance requirement of the federal award and the Uniform Guidance. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend the Organization document procurement policies in a formal written procurement policy that contains all required elements of and conforms to the requirements of the Uniform Guidance. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Corrective Actions Planned To address the deficiency in internal controls over compliance with respect to procurement, CHC will implement the following corrective actions: CHC will develop and implement a written procurement policy that conforms to the Uniform Guidance.; CHC will ensure sta􀀁 receive adequate training on the procurement policy and the required methods of procurement to be made when making procurements with federal awards. Responsible Person(s): CHC President, Rob Dibble as Primary; CHC Vice President Betsy Gordon as Backup Corrective Action Plan Dates: Schedule implementation starts: February 1, 2026; Staff training starts: March 1, 2026; Review process in effect starts: April 1, 2026

Categories

Procurement, Suspension & Debarment Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1172858 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.60M
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $737,014
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $63,235