Finding 1206388 (2024-007)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2026-04-10
Audit: 398386
Auditor: CBIZ CPAS

AI Summary

  • Core Issue: AEA lacks a formal written procurement policy that meets OMB requirements for suspension and debarment.
  • Impacted Requirements: This non-compliance affects adherence to 2 CFR Part 200.317–200.327 of the Uniform Guidance.
  • Recommended Follow-Up: AEA should formally adopt a compliant procurement and suspension and debarment policy, even though no questioned costs were reported.

Finding Text

Criteria: Uniform Guidance 2 CFR Part 200.318 require that AEA have documented procurement procedures for procurement transactions under a Federal award or subaward. Condition: AEA follows the Weather Assistance Program Policies and Procedures Manual which has a procurement and suspension and debarment policy; however, AEA did not formally adopt a written policy that complies with the Office of Management and Budget’s (the “OMB”) requirements for procurement suspension and debarment. Cause: AEA did not formally adopt a written policy that complies with OMB requirements for procurement suspension and debarment. Effect: AEA is not in compliance with 2 CFR Part 200.317–200.327 of the Uniform Guidance. Questioned Costs: None reported. Context: Not applicable. Repeat Finding: Not applicable. Recommendation: Although there were no purchases in the audit period meeting the threshold for competitive bidding, we recommend that the AEA formally adopt a written procurement and suspension and debarment policy in accordance with the requirements. View of Responsible Officials: See management’s corrective action plan.

Corrective Action Plan

AEA agrees with the finding. Management acknowledges that, while the organization followed procurement guidance contained in the Weather Assistance Program Policies and Procedures Manual, it did not formally adopt an organization-wide written procurement and suspension and debarment policy fully compliant with 2 CFR Part 200.317–200.327. AEA will formally adopt a written procurement policy that incorporates all applicable Uniform Guidance requirements, including procurement methods, competition requirements, documentation standards, conflict-of-interest provisions, and procedures for suspension and debarment verification for covered transactions. Management will also implement related procedures and control documentation to support consistent application of the policy across federally funded programs. AEA will provide training to relevant personnel and will maintain documentation evidencing procurement review and suspension/debarment verification, where applicable. Management believes these corrective actions will bring the organization into compliance and reduce the risk of future noncompliance.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1206380 2024-005
    Material Weakness Repeat
  • 1206381 2024-006
    Material Weakness Repeat
  • 1206382 2024-007
    Material Weakness Repeat
  • 1206383 2024-005
    Material Weakness Repeat
  • 1206384 2024-006
    Material Weakness Repeat
  • 1206385 2024-007
    Material Weakness Repeat
  • 1206386 2024-005
    Material Weakness Repeat
  • 1206387 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $773,299
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $289,568