Finding 1227717 (2023-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2026-08-24
Audit: 409697
Auditor: BLUEARROW CPA

AI Summary

  • Core Issue: SWIWC failed to provide adequate documentation for procurement processes, violating federal requirements.
  • Impacted Requirements: Non-compliance with 2 CFR Section 200.214 and 200.318(i) regarding procurement records and procedures.
  • Recommended Follow-Up: Strengthen procurement controls and ensure complete documentation for all transactions, including approvals and vendor selection.

Finding Text

2023-003 Procurement, Suspension, and Debarment - (Material Weakness) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds 21.027 418-22 Criteria or Specific Requirement: In accordance with 2 CFR Section 200.214 of the Uniform Guidance states that SWIWC must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: During our testwork over procurement, for ten samples tested, SWIWC was unable to provide adequate supporting documentation demonstrating that required procurement procedures were performed in accordance with established policies and applicable Uniform Guidance requirements. Cause: SWIWC did not consistently follow or maintain adequate documentation of its established procurement policies and procedures. Effect: SWIWC did not demonstrate compliance with applicable procurement requirements under the Uniform Guidance. As a result, there is an increased risk that purchases may not be properly authorized, adequately supported, competitively procured, or otherwise compliant with federal requirements. Auditor's Recommendations: We recommend that SWIWC strengthen its procurement monitoring controls to ensure personnel consistently follow established procurement policies and procedures. SWIWC should also require complete documentation for each procurement transaction, including approvals, quotations or bids, vendor selection support, and other applicable procurement records.

Corrective Action Plan

Management Response: Management concurs with the finding. During the audit period, procurement documentation was not consistently maintained in a centralized manner sufficient to demonstrate full compliance with Uniform Guidance procurement requirements, although management believes procurement decisions were generally made in the best interests of the Organization. Since FY2023, SWIWC has significantly enhanced its procurement practices by implementing updated procurement policies aligned with Uniform Guidance, standardized procurement checklists, documented quote requirements, vendor selection documentation, SAM.gov verification procedures, approval workflows, and centralized procurement files. Staff have also received additional training regarding procurement documentation and federal compliance requirements. Management believes these corrective actions establish a substantially stronger procurement control environment and will support continued compliance with federal procurement standards. Anticipated Completion Date: Implemented 6/30/2026; ongoing monitoring. Responsible Party: Chief Financial Officer and Director of Finance, with applicable Program Managers responsible for providing programmatic documentation.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1227715 2023-001
    Material Weakness Repeat
  • 1227716 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $793,652
16.557 TRIBAL DOMESTIC VIOLENCE AND SEXUAL ASSAULT COALITIONS GRANT PROGRAM $110,659
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $2,557