FAC Explorer

Finding 1219122 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-26
Audit: 405064
Organization: Jsi Research and Training Institute, Inc. (MA)
Auditor: GRANT THORNTON LLP

AI Summary

  • Core Issue: Significant deficiencies in procurement controls led to irregularities and fraudulent vendor representations in a federal program.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: Strengthen procurement oversight with enhanced vendor due diligence, improved documentation verification, and centralized monitoring of high-risk procurements.

Finding Text

Finding 2025-001 Procurement Controls (Significant Deficiency) Federal Programs Assistance Listing and Program Title* U.S. Agency For International Development 98.001 USAID Foreign Assistance for Programs Overseas Prime Contract #AID-391-A-17-00002 Award Year: Fiscal Year Ended September 30, 2025 Repeat Finding - No Criteria: Under 2 CFR 200.303, non-federal entities are required to establish and maintain effective internal controls over federal awards to provide reasonable assurance that federal awards are managed in compliance with applicable laws, regulations, and award terms and conditions. Such controls should include appropriate vendor due diligence, procurement oversight, monitoring of high-risk transactions, verification of vendor representations, and review controls over advance payments and procurement documentation. Condition: The Organization identified procurement irregularities and fraudulent representations by a vendor associated with the acquisition of mobile X-ray equipment under a federally funded program in Pakistan. Subsequent investigation determined that: • procurement advertisements had not been properly published, • falsified procurement support documentation had been submitted, • vendor representations regarding geographic code compliance were inaccurate, • and procurement controls did not timely identify irregularities associated with vendor selection and advance payment processing. The investigation further identified deficiencies in procurement oversight, vendor verification procedures, and monitoring controls, including insufficient review of supporting procurement documentation and inadequate safeguards surrounding an advance payment to the vendor. Upon identification of the matter, the Organization conducted internal and external investigations, terminated the procurement arrangement, and reduced the amount charged to the contract by approximately $2.2 million. Cause: Procurement oversight and vendor monitoring controls within the affected program location were not sufficiently designed and/or operating effectively to verify vendor representations, assess procurement risk indicators, validate procurement support documentation, and monitor compliance with procurement requirements on a timely basis. Effect: Improper procurement-related charges were incurred by the Organization. Questioned Costs: None. Recommendations: We recommend the Organization continue strengthening procurement oversight and compliance monitoring controls, particularly for high-risk and international procurements, including: • enhanced vendor due diligence procedures, • verification of critical procurement documentation, • strengthened review and approval controls over advance payments, • additional monitoring of vendor certifications and compliance representations, • escalation procedures for procurement irregularities, • and increased centralized oversight of significant procurement activities. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and has implemented corrective actions, including enhanced procurement oversight procedures, additional monitoring controls, and remediation activities within the affected country operations.

Corrective Action Plan

Finding Number: 2025-001 Finding Title: Procurement Controls (Significant Deficiency) Name of Contact Person: Janice Clark, Chief Finance & Operations Officer Corrective actions implemented or in process include the following: 1. Enhanced Procurement Oversight and Centralized Review The Organization, building on its established procurement policies, implemented stricter headquarters oversight and approval requirements for higher-risk and higher-dollar procurements, including defined approval thresholds for procurement solicitations, evaluation activities, and contract execution. Specialized and international procurements now require additional senior-level review and involvement, regardless of value. 2. Strengthened Vendor Due Diligence and Market Research Procedures The Organization updated procurement procedures to require expanded documentation of vendor due diligence and market research activities, including enhanced validation of vendor qualifications, procurement support documentation, and vendor representations associated with federal procurements. 3. Enhanced Monitoring of Procurement Documentation and Compliance Requirements Management implemented strengthened review procedures over procurement advertisements, vendor certifications, geographic code compliance documentation, and other supporting procurement records. The revised procedures also require additional review and escalation for identified procurement irregularities or inconsistencies. 4. Advance Payment and Approval Controls The Organization implemented revised controls governing advance payments, including enhanced approval requirements for significant prepayments and additional supporting documentation requirements for high-risk payment arrangements. 5. Procurement Evaluation and Technical Assistance The Organization enhanced procurement evaluation oversight by requiring additional Headquarters participation in evaluation activities for procurements exceeding defined thresholds. In addition, the Organization engaged specialized procurement and logistics resources to provide technical assistance and support for international procurement activities. 6. Personnel Actions and Training The Organization took personnel actions in response to the investigation findings and implemented enhanced procurement and compliance training for relevant personnel involved in procurement and grants management activities. Management believes these corrective actions appropriately address the control deficiencies identified in the finding and strengthen the Organization’s internal control over compliance related to procurement activities under federally funded programs. Anticipated Completion Date: Substantially completed as of April 6, 2026, with ongoing monitoring and training activities continuing through fiscal year 2026.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management Reporting Significant Deficiency

Other Findings in this Audit

  • 1219085 2025-001
    Material Weakness Repeat
  • 1219086 2025-001
    Material Weakness Repeat
  • 1219087 2025-001
    Material Weakness Repeat
  • 1219088 2025-001
    Material Weakness Repeat
  • 1219089 2025-001
    Material Weakness Repeat
  • 1219090 2025-001
    Material Weakness Repeat
  • 1219091 2025-001
    Material Weakness Repeat
  • 1219092 2025-001
    Material Weakness Repeat
  • 1219093 2025-001
    Material Weakness Repeat
  • 1219094 2025-001
    Material Weakness Repeat
  • 1219095 2025-001
    Material Weakness Repeat
  • 1219096 2025-001
    Material Weakness Repeat
  • 1219097 2025-001
    Material Weakness Repeat
  • 1219098 2025-001
    Material Weakness Repeat
  • 1219099 2025-001
    Material Weakness Repeat
  • 1219100 2025-001
    Material Weakness Repeat
  • 1219101 2025-001
    Material Weakness Repeat
  • 1219102 2025-001
    Material Weakness Repeat
  • 1219103 2025-001
    Material Weakness Repeat
  • 1219104 2025-001
    Material Weakness Repeat
  • 1219105 2025-001
    Material Weakness Repeat
  • 1219106 2025-001
    Material Weakness Repeat
  • 1219107 2025-001
    Material Weakness Repeat
  • 1219108 2025-001
    Material Weakness Repeat
  • 1219109 2025-001
    Material Weakness Repeat
  • 1219110 2025-001
    Material Weakness Repeat
  • 1219111 2025-001
    Material Weakness Repeat
  • 1219112 2025-001
    Material Weakness Repeat
  • 1219113 2025-001
    Material Weakness Repeat
  • 1219114 2025-001
    Material Weakness Repeat
  • 1219115 2025-001
    Material Weakness Repeat
  • 1219116 2025-001
    Material Weakness Repeat
  • 1219117 2025-001
    Material Weakness Repeat
  • 1219118 2025-001
    Material Weakness Repeat
  • 1219119 2025-001
    Material Weakness Repeat
  • 1219120 2025-001
    Material Weakness Repeat
  • 1219121 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.260 FAMILY PLANNING PERSONNEL TRAINING $4.50M
98.U03 Uganda USAID/PUMRA 14070 $3.79M
93.U01 Uniform Data System (UDS) Training and Technical Assistance $2.70M
93.088 ADVANCING SYSTEM IMPROVEMENTS FOR KEY ISSUES IN WOMEN'S HEALTH $2.38M
93.297 TEENAGE PREGNANCY PREVENTION PROGRAM $1.58M
93.U02 BPHC3 C 3125 Health Center Workforce Survey Evaluation and Technical Assistance $649,531
10.608 FOOD FOR EDUCATION $597,450
93.U03 Technical Assistance and Training of Uniform Data Systems for Health Centers (UDS) $538,853
93.387 NATIONAL AND STATE TOBACCO CONTROL PROGRAM $472,328
93.211 TELEHEALTH PROGRAMS $471,955
93.217 FAMILY PLANNING SERVICES $461,738
10.U57 WFP/USDA/CAM/MGD FFE $421,198
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $414,834
98.U27 RTI/USAID/CAM/IPEA 62478 $340,419
17.401 INTERNATIONAL LABOR PROGRAMS $268,095
93.426 THE NATIONAL CARDIOVASCULAR HEALTH PROGRAM $266,974
93.977 SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND CONTROL GRANTS $245,619
93.U04 AIDS Education Training Centers (AETC) Evaluation Implementation Contract. $235,143
98.007 FOOD FOR PEACE DEVELOPMENT ASSISTANCE PROGRAM (DAP) $228,754
66.615 ENVIRONMENTAL JUSTICE THRIVING COMMUNITIES GRANTMAKING PROGRAM (EJ TCGM) $217,618
93.788 OPIOID STR $202,301
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $199,918
84.U37 DRAW2_JFF-OCTAE_FY25-27 $176,900
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $162,700
97.012 BOATING SAFETY FINANCIAL ASSISTANCE $161,628
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $146,893
84.U36 EARN-2_RTI-IET-DOE OCTAE $135,542
98.U04 Zambia eSCMIS 13933 $132,064
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $131,433
93.917 HIV CARE FORMULA GRANTS $125,561
93.070 ENVIRONMENTAL PUBLIC HEALTH AND EMERGENCY RESPONSE $122,649
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $118,889
98.U05 GHSC-TA-TZ 13628 $102,263
93.145 HIV-RELATED TRAINING AND TECHNICAL ASSISTANCE $101,988
84.U04 MSG_ATB_OCTAE-DE-DAEL $96,035
84.U03 AIR-IET/OCTAE/NCTN 61296 $88,461
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $88,450
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $86,689
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $83,921
93.129 STATE AND REGIONAL PRIMARY CARE ASSOCIATIONS (PCAS), NATIONAL TECHNICAL ASSISTANCE PROGRAMS (NTAPS), AND HEALTH CENTERED CONTROLLED NETWORKS (HCCNS) $81,972
16.838 COMPREHENSIVE OPIOID, STIMULANT, AND SUBSTANCE USE PROGRAM $72,833
98.U42 Strengthening Livelihoods $69,598
93.270 VIRAL HEPATITIS PREVENTION AND CONTROL $65,640
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $64,798
93.988 COOPERATIVE AGREEMENTS FOR DIABETES CONTROL PROGRAMS $61,976
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $61,857
19.800 WEAPONS REMOVAL AND ABATEMENT $61,638
93.130 COOPERATIVE AGREEMENTS TO STATES/TERRITORIES FOR THE COORDINATION AND DEVELOPMENT OF PRIMARY CARE OFFICES $57,511
66.616 ENVIRONMENTAL AND CLIMATE JUSTICE COMMUNITY CHANGE GRANTS PROGRAM $57,117
93.778 GRANTS TO STATES FOR MEDICAID $56,737
98.U99 HAI Nigeria ACE $55,068
93.073 BIRTH DEFECTS AND DEVELOPMENTAL DISABILITIES - PREVENTION AND SURVEILLANCE $49,732
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $47,886
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $43,419
93.945 ASSISTANCE PROGRAMS FOR CHRONIC DISEASE PREVENTION AND CONTROL $41,232
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $39,730
93.493 CONGRESSIONAL DIRECTIVES $38,362
93.940 HIV PREVENTION AND SURVEILLANCE ACTIVITIES-HEALTH DEPARTMENT BASED $34,972
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $34,048
84.425 EDUCATION STABILIZATION FUND $32,449
45.312 NATIONAL LEADERSHIP GRANTS $29,348
93.436 WELL-INTEGRATED SCREENING AND EVALUATION FOR WOMEN ACROSS THE NATION (WISEWOMAN) $27,304
93.495 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $27,109
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $27,095
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $22,654
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $22,500
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $21,884
84.U20 RTI/DOE/IET/NCTN 61297 $21,223
84.U14 MATHEMATICA/NCTN 61282 $17,410
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $15,190
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $13,509
98.U01 Zambia SAFE 13690 $13,414
93.928 SPECIAL PROJECTS OF NATIONAL SIGNIFICANCE $11,332
84.002A NELRC CT FY25 $11,312
84.U19 RTI/OCTAE-EARN/NCTN 61272 $11,307
66.032 STATE AND TRIBAL INDOOR RADON GRANTS $10,447
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $9,444
93.939 HIV PREVENTION ACTIVITIES NON-GOVERNMENTAL ORGANIZATION BASED $7,074
84.U02 AIR OCTAE TSTM2 $6,660
84.U01 AIR OCTAE NRS TA $5,899
66.605 PERFORMANCE PARTNERSHIP GRANTS $5,712
93.197 CHILDHOOD LEAD POISONING PREVENTION PROJECTS, STATE AND LOCAL CHILDHOOD LEAD POISONING PREVENTION AND SURVEILLANCE OF BLOOD LEAD LEVELS IN CHILDREN $5,368
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $5,112
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $4,001
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $3,669
93.318 PROTECTING AND IMPROVING HEALTH GLOBALLY: BUILDING AND STRENGTHENING PUBLIC HEALTH IMPACT, SYSTEMS, CAPACITY AND SECURITY $3,380
84.305 EDUCATION RESEARCH, DEVELOPMENT AND DISSEMINATION $2,067
84.U11 JFF/OCTAE/DIGTL LIT 61273 $23
98.U02 UGANDA RHITES Lango 13759 $-178,593