Finding 1179284 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-12

AI Summary

  • Core Issue: Catholic Charities did not follow its own procurement and vendor verification procedures, leading to potential compliance risks.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and 2 CFR 200.318 regarding internal controls and procurement policies.
  • Recommended Follow-Up: Enhance internal controls to ensure all procurement and vendor checks are completed before transactions are made.

Finding Text

Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement and suspension and debarment procedures that conform to applicable federal standards regarding procurement and testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing for procurement and one for suspension and debarment. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding the process of obtaining quotes to support procurement and testing vendors for suspension and debarment were followed. Effect: Payments could be made to vendors who have higher costs than other vendors or who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 17 vendors out of 83 total transactions were selected for testing, which accounted for $81,494 of $681,188 federal program expenditures. Repeat Finding from Prior Year(s): Yes, 2024-002 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all procurement and suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Procurement Finding 2025-003 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding the process of obtaining quotes to support procurement and testing vendors for suspension and debarment were followed. Corrective Action Plan: Catholic Charities is enhancing procurement oversight and compliance by centralizing procurement documentation, strengthening review and approval controls, and increasing management oversight. Procurement records will be centrally maintained and made accessible to the Accounting and Compliance Departments, in order to support monitoring and audit readiness. Updated training and standardized compliance tools are in the process of implementation, to reinforce consistent application of federal procurement requirements. In addition, Catholic Charities is strengthening vendor oversight through a centralized vendor management process that ensures ongoing monitoring for suspension and debarment. The Compliance Department already runs regular debarment/suspension checks against all vendors engaged in any form of agreement (e.g., contract, grant, MOU, amendment, etc.) but has no visibility to vendors not tied to an agreement. To solve this, the Compliance Department will request a report from the Accounting Department, which lists all vendors paid and will run debarment and suspension checks. All new vendors will be reviewed prior to engagement, and existing vendors will be reviewed on a recurring basis using this report. Responsible Individuals: Primary: Carys Church, Procurement Manager Secondary: Elizabeth Knight, Chief Compliance Officer; Mary Ammer, Sr. Director of Accounting and Finance Anticipated Completion Date: April 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1179262 2025-002
    Material Weakness Repeat
  • 1179263 2025-002
    Material Weakness Repeat
  • 1179264 2025-002
    Material Weakness Repeat
  • 1179265 2025-002
    Material Weakness Repeat
  • 1179266 2025-002
    Material Weakness Repeat
  • 1179267 2025-002
    Material Weakness Repeat
  • 1179268 2025-002
    Material Weakness Repeat
  • 1179269 2025-002
    Material Weakness Repeat
  • 1179270 2025-003
    Material Weakness Repeat
  • 1179271 2025-003
    Material Weakness Repeat
  • 1179272 2025-003
    Material Weakness Repeat
  • 1179273 2025-003
    Material Weakness Repeat
  • 1179274 2025-003
    Material Weakness Repeat
  • 1179275 2025-003
    Material Weakness Repeat
  • 1179276 2025-003
    Material Weakness Repeat
  • 1179277 2025-003
    Material Weakness Repeat
  • 1179278 2025-003
    Material Weakness Repeat
  • 1179279 2025-003
    Material Weakness Repeat
  • 1179280 2025-003
    Material Weakness Repeat
  • 1179281 2025-003
    Material Weakness Repeat
  • 1179282 2025-003
    Material Weakness Repeat
  • 1179283 2025-003
    Material Weakness Repeat
  • 1179285 2025-004
    Material Weakness Repeat
  • 1179286 2025-004
    Material Weakness Repeat
  • 1179287 2025-004
    Material Weakness Repeat
  • 1179288 2025-004
    Material Weakness Repeat
  • 1179289 2025-004
    Material Weakness Repeat
  • 1179290 2025-004
    Material Weakness Repeat
  • 1179291 2025-004
    Material Weakness Repeat
  • 1179292 2025-004
    Material Weakness Repeat
  • 1179293 2025-004
    Material Weakness Repeat
  • 1179294 2025-004
    Material Weakness Repeat
  • 1179295 2025-004
    Material Weakness Repeat
  • 1179296 2025-004
    Material Weakness Repeat
  • 1179297 2025-004
    Material Weakness Repeat
  • 1179298 2025-004
    Material Weakness Repeat
  • 1179299 2025-004
    Material Weakness Repeat
  • 1179300 2025-005
    Material Weakness Repeat
  • 1179301 2025-005
    Material Weakness Repeat
  • 1179302 2025-005
    Material Weakness Repeat
  • 1179303 2025-005
    Material Weakness Repeat
  • 1179304 2025-005
    Material Weakness Repeat
  • 1179305 2025-005
    Material Weakness Repeat
  • 1179306 2025-006
    Material Weakness Repeat
  • 1179307 2025-006
    Material Weakness Repeat
  • 1179308 2025-006
    Material Weakness Repeat
  • 1179309 2025-006
    Material Weakness Repeat
  • 1179310 2025-006
    Material Weakness Repeat
  • 1179311 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.008 NON-PROFIT SECURITY PROGRAM $45,599
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $12,890
14.267 CONTINUUM OF CARE PROGRAM $10,479
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $10,000