Finding Text
Eligibility and Procurement Federal Agency: U.S. Department of Justice Federal Program Name: Services for Trafficking Victims Assistance Listing Number: 16.320 Federal Award Identification Number and Year: 15POVC‑23‑GK‑02725‑HT; 15POVC‑24‑GG‑01548‑HT Pass-Through Agency: Palm Beach County Board of County Commissioners Award Period: October 1, 2023 – September 30, 2026; October 1, 2024 – September 30, 2027 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria: Eligibility determinations must be reviewed by an individual other than the preparer to ensure only eligible participants are served. In addition, recipients are required to maintain written procurement policies and procedures that comply with Uniform Guidance requirements, including procedures for procurements exceeding the micro‑purchase threshold. Condition: During our testing, we noted the Organization did not have adequate internal controls to ensure compliance with eligibility and procurement requirements. Specifically, eligibility assessments were not reviewed by an individual other than the preparer, and the Organization’s procurement policy did not address procurement requirements for vendors other than construction, as required by Uniform Guidance. Questioned costs: None Context: All nine eligibility assessments selected for testing were not reviewed by an individual other than the preparer. The review of eligibility assessments is the sole key control over participant eligibility for this program and is therefore pervasive. Additionally, while the Organization maintains a procurement policy for construction vendors, the policy does not address procurement requirements applicable to other vendor types, increasing the risk of noncompliant purchasing practices. Cause: The Organization lacked sufficient review procedures over eligibility determinations and did not maintain comprehensive procurement policies that address all Uniform Guidance procurement requirements. Effect: Without independent review of eligibility determinations, the Organization could allow ineligible participants into the program. Inadequate procurement policies increase the risk that purchases are made inconsistently or in noncompliance with federal requirements, potentially resulting in disallowed costs or questioned expenditures. Repeat finding: No Recommendation: Management should implement a review process requiring eligibility assessments to be reviewed by an individual other than the preparer and update procurement policies to fully comply with Uniform Guidance requirements, including procedures for procurements exceeding the micro‑purchase threshold. Views of responsible officials: There is no disagreement with the audit finding.