Finding 1208272 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-04-21
Audit: 399300
Organization: Trilogy, Inc. (IL)

AI Summary

  • Core Issue: The Organization failed to verify that a vendor was not suspended or debarred before entering into a contract.
  • Impacted Requirements: Compliance with 2 CFR sections 200.212, 200.318(h), and 180.300, which mandate verification of vendor eligibility.
  • Recommended Follow-Up: Document the use of SAM.gov for vendor checks and consider monthly third-party verifications for all new and existing vendors.

Finding Text

Federal agency: Department of Housing and Urban Development Federal program title: Continuum of Care Program FALN Number: 14.267 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: December 1, 2024 – November 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance Criteria or specific requirement: 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 Organization did not verify that a vendor utilized was not suspended, debarred, or otherwise excluded prior to entering into a transaction. Questioned costs: None Context: This condition impacted one (1) of one (1) transaction selected for testing. During the audit, the vendor was checked via SAM.gov and determined to not be included as suspend or debarred. Cause: Oversight. Effect: The Organization could potentially enter into a transaction with an entity that has been suspended or debarred. Repeat Finding: No Recommendation: We recommend that the Organization retain documentation that SAM.gov was used to verify that vendors are not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. To the extent practicable, the Organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Suspension and Debarment – Assistance Listing No. 14.267 Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will update procurement procedures to require documented SAM.gov verification for all new vendors prior to contract execution and periodically for existing vendors. Evidence of verification (e.g., screenshots or confirmation reports) will be retained in procurement files. Management will also evaluate engaging a third‑party service to perform monthly suspension and debarment screenings. Compliance will be reviewed as part of routine procurement oversight. Name(s) of the contact person(s) responsible for corrective action: Scott Russell Planned completion date for corrective action plan: 6/30/2026

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 1208271 2025-002
    Material Weakness Repeat
  • 1208273 2025-004
    Material Weakness Repeat
  • 1208274 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $1.82M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $300,356
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $260,442
93.150 Projects for Assistance in Transition from Homelessness $199,874
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $158,509
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $134,641