Finding 1221506 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-06-30
Audit: 405803
Organization: Holy Cross Services, Inc. (MI)
Auditor: DOEREN MAYHEW

AI Summary

  • Core Issue: The Organization failed to obtain required price quotes for vendor selections exceeding the micro-purchase threshold, violating federal procurement standards.
  • Impacted Requirements: Noncompliance with 2 CFR §200.320, which mandates full and open competition in managing federal funds.
  • Recommended Follow-Up: Assign a knowledgeable individual to oversee compliance for all projects and ensure documentation of all communications with the grantor regarding procurement deviations.

Finding Text

2025-001 Finding Type Material Weakness, Noncompliance – Procurement Federal Program COVID-19 Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Criteria Pursuant to 2 CFR §200.320, federal funds must be managed in a manner that ensures full and open competition. The procurement method used for each transaction must be appropriate based on the dollar amount and conditions. Condition During our testing, we noted that the Organization did not obtain price quotes prior to selecting vendors whose expenditures exceeded the micro-purchase threshold. Cause This issue originated in the prior year and impacted various current year expenditures as well. The Organization has the proper procurement policies in place. However, due to a short timeframe for the project, an individual within the Organization’s management did not comply with the policy in an attempt to expedite the project’s completion. The Organization’s internal controls failed to detect and correct the noncompliance. The individual in management who made this decision is no longer employed at the Organization; therefore, documentation on the matter is insufficient and current management is unaware of the communications that occurred with the grantor concerning the timing of gathering price quotes and the necessity to expedite the process. Effect The Organization incurred expenditures of $159,595 that were not in compliance with procurement standards. Questioned Costs Known questioned costs - $159,595 Questioned costs were identified by the Organization as instances of noncompliance prior to the commencement of audit testing. We performed audit testing over a sample of 25 procurement transactions and did not identify any additional instances of noncompliance beyond those reported by the Organization. Identification of a Repeat Finding This is a repeat finding from the prior year’s audit, finding number 2024-001. Recommendation We recommend that the Organization designate an additional responsible party who has knowledge of federal procurement requirements review all projects to ensure compliance. Additionally, all correspondence with the grantor regarding deviations from these requirements should be maintained, including evidence of grantor pre-approval. Response As noted in the corrective action plan, management agrees with this finding.

Corrective Action Plan

HCS currently has in place Policy 2095 – Procurement Standards, which requires obtaining three quotes for goods and services above $5,000. This policy was not followed by the agency’s leadership when the goods and services referenced in this finding were procured, despite counsel recommending that it be followed. Corrective action taken during the prior year included termination of the individual who violated the policy. Beginning on 11/15/2024, the above-referenced policy has been, and will continue to be, adhered to. Because certain expenses related to the prior-year procurement activity trailed into the 2024–2025 fiscal year, the finding was repeated; however, no new violations of Policy 2095 occurred in 2024–2025. HCS will continue to monitor procurement activity and maintain full compliance with Policy 2095 going forward.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1221503 2025-001
    Material Weakness Repeat
  • 1221504 2025-001
    Material Weakness Repeat
  • 1221505 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $736,380
64.024 VA HOMELESS PROVIDERS GRANT AND PER DIEM PROGRAM $363,411
16.049 SUPPORTING VULNERABLE AND AT-RISK YOUTH TRANSITIONING OUT OF FOSTER CARE $262,376
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $78,395
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $29,971