Finding 1219163 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-26

AI Summary

  • Core Issue: MSP failed to verify vendor suspension and debarment for payments over $25,000, violating federal compliance requirements.
  • Impacted Requirements: Non-federal entities must check for exclusions using SAM, collect certifications, or include clauses in contracts as per 2 CFR Part 180.
  • Recommended Follow-Up: MSP should implement internal processes to retain documentation of vendor checks before disbursing funds over $25,000.

Finding Text

Finding 2025-001 – Procurement, suspension and debarment Assistance Listing #: 14.267 Criteria: In accordance with the Uniform Guidance, recipients who receive federal funding shall fully comply with Subpart C of 2 CFR Part 180, which requires nonfederal entities to verify that the person/entity with whom you intend to do business is not excluded or disqualified, if the expected payments are equal to or exceed $25,000. A non-federal entity has three options for performing this verification: 1) checking SAM exclusions; 2) collecting a certification from that person; or 3) adding a clause or condition to the covered transaction with that person. Condition: During fiscal year 2025, MSP contracted with several vendors for products and services who were paid more than $25,000. There was no evidence documenting that these vendors were checked for suspension and debarment prior to payment. Cause: There were several vendors who were paid cumulatively more than $25,000 during fiscal year 2025. Most of these payments related to payments to client landlords. Documentation was not retained and we were unable to verify that the vendors had been checked for suspension and debarment. Effect: We were unable to determine that the required checks for suspension and debarment had been performed as the documentation was not retained. Questioned Costs: N/A Repeat Finding: Yes Recommendation: We recommend MSP perform follow its internal processes and retain documentation of the suspension and debarment check in the vendor file as support for vendors who are paid or expected to be paid over $25,000 prior to funds being disbursed. Response: MSP will still perform the verifications by using the System for Award Management (SAM) and Office of Inspector General (OIG) websites. We will start saving documentation that will support the required vendor verifications.

Corrective Action Plan

Finding 2025-001: Procurement, Suspension, and Debarment Assistance Listing #: 14.267 Recommendation: Delong & Stang recommend MSP perform its internal processes and retain documentation of the suspension and debarment check in the vendor file as support for vendors who are paid or expected to be paid over $25,000 prior to funds being disbursed. Management Response: MSP agrees with the recommendation and will strengthen its vendor verification process by ensuring that all vendors expected to receive payments of $25,000 or more are screened through SAM and OIG prior to contract execution or payment. Documentation supporting these verifications will be retained in the vendor file and reviewed periodically for compliance. Action Plan: 1. Update the procurement checklist to include mandatory SAM and OIG verification before payment approval. 2. Create a standardized electronic filing system for verification documentation. 3. Train finance and program staff on suspension and debarment requirements. 4. Conduct quarterly reviews of vendors exceeding the $25,000 threshold to ensure compliance and documentation retention. 5. Assign responsibility to the Finance Manager for monitoring and maintaining compliance records.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1219155 2025-002
    Material Weakness Repeat
  • 1219156 2025-002
    Material Weakness Repeat
  • 1219157 2025-002
    Material Weakness Repeat
  • 1219158 2025-002
    Material Weakness Repeat
  • 1219159 2025-001
    Material Weakness Repeat
  • 1219160 2025-002
    Material Weakness Repeat
  • 1219161 2025-001
    Material Weakness Repeat
  • 1219162 2025-002
    Material Weakness Repeat
  • 1219164 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $170,749
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $3,690