Finding 1217539 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-15

AI Summary

  • Core Issue: The YMCA failed to verify that two vendors were not suspended or debarred before engaging them for contracts over $25,000.
  • Impacted Requirements: This noncompliance relates to 2 CFR Part 180, which mandates checks on excluded parties for procurement contracts.
  • Recommended Follow-Up: The YMCA should update and enforce its policies on federal award compliance to prevent future lapses.

Finding Text

Procurement, Suspension, and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. COVID-19 Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Passed through the City of Toledo, Ohio; Award Number 2021-16100-5WAYMANPALNEI. Criteria. Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. Condition. For two out of two vendors selected for testing, the YMCA was unable to provide evidence that the vendors were not suspended, debarred, or otherwise excluded at the time they were engaged to provide goods or services. Cause. The YMCA does not have the proper internal controls in place to ensure that the appropriate procedures are being followed for covered transactions in accordance with the requirements of the Uniform Guidance. Effect. As a result of this condition, the YMCA was exposed to an increased risk that disbursements of federal awards could be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs, and the vendors in question were not actually suspended or debarred. Recommendation. We recommend that the YMCA review its written policies and procedures over federal awards with employees responsible for grant compliance to ensure that they are being followed consistently. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Procurement, Suspension, and Debarment Auditor Description of Criteria, Condition, and Effect: Under the requirements of 2 CFR Part 180 covered transactions for procurement and nonprocurement contracts that are expected to equal or exceed $25,000, the grantee must verify that the party being awarded procurement and nonprocurement contract is not suspended, debarred, or otherwise excluded by checking the list of excluded parties, obtaining certification from the vendor or subrecipient, or including a clause or condition to the covered transaction with that entity. For two out of two vendors selected for testing, the YMCA was unable to provide evidence that the vendors were not suspended, debarred, or otherwise excluded at the time they were engaged to provide goods or services. As a result of this condition, the YMCA was exposed to an increased risk that disbursements of federal awards could be made to vendors suspended or debarred by the federal government. Auditor Recommendation: We recommend that the YMCA review its written policies and procedures over federal awards with employees responsible for grant compliance to ensure that they are being followed consistently. Corrective Action: YMCA relied upon outside legal counsel for guidance in the procurement process. In the future, YMCA will perform this procedure or ensure that legal counsel performs this procedure. Responsible Person: Phil Platz, CFO Anticipated Completion Date: 6/12/2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1217538 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $6.52M
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $124,377
20.205 HIGHWAY PLANNING AND CONSTRUCTION $47,561
93.988 COOPERATIVE AGREEMENTS FOR DIABETES CONTROL PROGRAMS $10,000
93.945 ASSISTANCE PROGRAMS FOR CHRONIC DISEASE PREVENTION AND CONTROL $9,000