Finding 1214198 (2022-006)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2022

Accepted

2026-05-08

Audit: 400920

Organization: Open Door Ministries of High Point, Inc. (NC)

Auditor: CLIFTONLARSONALLEN LLP

AI Summary

Core Issue: The Organization lacks documented procurement policies, leading to a material weakness in internal controls over compliance.
Impacted Requirements: Non-compliance with 2 CFR 200.318(a) and related procurement standards, affecting federal award management.
Recommended Follow-Up: Implement a formal written procurement policy and establish 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: E20DW37001-2022 and ODMH543-1306-659-PC-21 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 – 6/30/2022 and 10/1/2021 – 9/30/2022 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: Yes 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

Other Findings in this Audit

1214197 2022-006

Material Weakness Repeat
1214199 2022-007

Material Weakness Repeat
1214200 2022-008

Material Weakness Repeat
1214201 2022-008

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
64.024	VA HOMELESS PROVIDERS GRANT AND PER DIEM PROGRAM	$284,075
14.231	EMERGENCY SOLUTIONS GRANT PROGRAM	$207,656
14.267	CONTINUUM OF CARE PROGRAM	$201,767