Finding 1174705 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-02-20

AI Summary

  • Core Issue: The Agency failed to verify that a vendor was not suspended or debarred before engaging in contracts, which is a significant internal control deficiency.
  • Impacted Requirements: Compliance with 2 CFR sections 200.212, 200.318(h), and 180.300, which mandate verification of vendor eligibility.
  • Recommended Follow-Up: Update the procurement policy to include vendor verification procedures and maintain documentation to support compliance.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL178L5T172302 - 2024 IL0315L5T142316 - 2024 IL1651L5Y142305 - 2024 IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL0315LST142215 – 2023 Award Periods: August 1, 2023 – July 31, 2024; August 1, 2024 – July 31, 2025; July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Agency did not perform the verification of a recurring vendor not suspended or debarred until subsequent to year end. Questioned Costs: None Context: The Agency procured grant writing services and made rental assistance payments to the vendor without performing the verification for the vendor not being suspended or debarred until after the fiscal year end. Cause: Unknown Effect: Formalized procedures should be in place to ensure the Agency does not engage with vendors that are debarred, suspended, or otherwise excluded. Repeat Finding: This finding is a repeat of finding 2024-002. Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Views of Responsible Officials: There is no disagreement with this audit finding.

Corrective Action Plan

Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for debarred, suspended, or excluded and documentation maintained to support the determination. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 1174704 2025-001
    Material Weakness Repeat
  • 1174706 2025-003
    Material Weakness Repeat
  • 1174707 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $910,465
14.261 NATIONAL HOMELESS DATA ANALYSIS PROJECT (NHDAP) $476,346
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $361,616
93.667 SOCIAL SERVICES BLOCK GRANT $226,489
93.276 DRUG-FREE COMMUNITIES SUPPORT PROGRAM GRANTS $98,826
93.569 COMMUNITY SERVICES BLOCK GRANT $18,912