Finding 1205255 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-31
Audit: 396959
Organization: Big Picture Philadelphia (PA)

AI Summary

  • Core Issue: The organization lacks formal policies and procedures for compliance with procurement, conflict of interest, suspension, and debarment requirements.
  • Impacted Requirements: Compliance with 2 CFR Part 200 is not met, increasing the risk of noncompliance.
  • Recommended Follow-Up: Management should develop and document comprehensive policies to ensure compliance with procurement and conflict of interest guidelines.

Finding Text

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: Pennsylvania Commission on Crime and Delinquency Contract Number(s): 2022-CV-CV-39777 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance of Procurement, Conflict of Interest, Suspension and Debarment - Other Matter Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, conflict of interest, suspension, and debarment. The Organization should have documented internal controls designed to ensure compliance with those provisions. Condition and Context: During our testing of procurement, conflict of interest, suspension and debarment practices, we noted that the organization did not have formal policies and procedures in place or documented that adhere to the requirements of Uniform Guidance on procurement, conflict of interest, suspension, and debarment. Questioned Costs: The questioned costs are unknown. Cause: The Organization did not have adequate policies and procedures in place and formally documented surrounding procurement, conflict of interest, suspension, and debarment to adhere to the requirements of Uniform Guidance. Effect: The lack of proper policies, procedures, and internal controls over the compliance requirements for procurement, conflict of interest, suspension and debarment provide the opportunity for noncompliance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management develop and formally document policies and procedures to ensure an adequate review process is in place to monitor new and potential contractors to determine whether a conflict of interest exists and that the procurement, conflict of interest, suspension and debarment procedures are being followed in accordance to Uniform Guidance. Views of responsible officials and planned corrective actions: Please refer to Big Picture Philadelphia’s Corrective Action Plan.

Corrective Action Plan

- Significant Deficiency in Internal Control over Compliance of Procurement, Conflict of Interest, Suspension and Debarment - Other Matters Recommendation: We recommend that management continue to develop policies and procedures to ensure an adequate review process is in place to monitor new and potential contractors to determine whether a conflict of interest exists and that the procurement, conflict of interest, suspension, and debarment policies and procedures are being followed in accordance with Uniform Guidance. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: The School acknowledges the finding and agrees with the recommendation. The School has established internal control procedures in accordance with Uniform Guidance and believes these procedures are operating as intended. However, the School recognizes the need to enhance the consistency of documentation supporting these processes. Management will reinforce existing procedures and ensure that appropriate documentation is consistently maintained to support compliance with procurement, conflict of interest, and suspension and debarment requirements. Name of the contact person responsible for corrective action: Tia Hall, Executive Director Planned completion date for corrective action plan: June 30, 2026

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $858,718
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $186,140