Finding 1181988 (2021-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2021
Accepted
2026-03-23

AI Summary

  • Core Issue: The Organization lacks documented procurement policies and procedures, leading to non-compliance with federal standards.
  • Impacted Requirements: Failure to meet 2 CFR 200.318(a) and related procurement standards affects compliance with federal regulations.
  • Recommended Follow-Up: Adopt a formal procurement policy and implement controls to monitor vendor spending and ensure compliance with procurement procedures.

Finding Text

Federal Agency: Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Federal Award Identification Number and Year: E20DW37001-2021 and ODMH543-1095-659-CM-20 Pass-Through Agency: North Carolina Department of Health and Human Services, Division of Aging and Adult Services Pass-Through Number(s): 00041416 Award Period: 7/29/2020 - 6/30/2021 and 10/1/2019 - 9/30/2021 Type of Finding: Material Weakness in Internal Control over Compliance Criteria or specific requirement: In accordance with 2 CFR 200.318 (a), the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. Condition: During our testing, we noted the Organization did not have documented procurement policies and procedures. Questioned costs: None Context: During our testing, we noted the Organization did not have documented procurement policies. Cause: The Organization did not have established procurement policies and did not have internal controls designed to ensure compliance with Federal procurement standards. Effect: The Organization was not in compliance with the Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Repeat Finding: No Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. Views of responsible officials: There is no disagreement with the finding.

Corrective Action Plan

Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has developed and implemented a formal written procurement policy aligned with applicable federal requirements and organizational purchasing practices. The policy includes required procurement methods, thresholds, documentation standards, conflict-of interest provisions, and approval authority levels. In addition, the Organization has implemented internal monitoring controls to track cumulative vendor spending throughout the fiscal year and to ensure that procurement procedures are properly initiated when vendor costs approach or exceed established procurement thresholds. Staff responsible for purchasing and vendor management have been trained on the updated requirements and documentation expectations. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1181987 2021-006
    Material Weakness Repeat
  • 1181989 2021-007
    Material Weakness Repeat
  • 1181990 2021-008
    Material Weakness Repeat
  • 1181991 2021-009
    Material Weakness Repeat
  • 1181992 2021-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
64.024 VA HOMELESS PROVIDERS GRANT AND PER DIEM PROGRAM $339,550
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $334,029
14.267 CONTINUUM OF CARE PROGRAM $196,327