Finding Text
Finding 2025-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment Identification of the federal program: Program Titles: Youth Homeless Demonstration Program Assistance Listing Number: 14.267 Award Identification: OH0747Y5E022401, OH0748Y5E022100 Federal Agencies: United States Department of Housing and Urban Development Pass-through entities: Cuyahoga County (Office of Homeless Services) Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding the Suspension and Debarment compliance requirement for the Youth Homeless Demonstration Program. Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not provide for the retention of documentation to evidence such review and approval was completed. Effect: There is an increased risk that the organization may enter into covered transactions with parties that are suspended and debarred. Questioned costs: None Context: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding the Suspension and Debarment compliance requirement for two out of two vendors tested under the Youth Homeless Demonstration Program. Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.