Finding 1228974 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-06

AI Summary

  • Core Issue: ECA failed to document checks for contractors' debarment or suspension status, violating federal guidelines.
  • Impacted Requirements: Non-compliance with debarment and suspension standards set by DCED, DNREC, and OMB for federally funded contracts.
  • Recommended Follow-up: ECA should implement a policy to ensure contractor checks are performed and documented before engagement.

Finding Text

Contractor Debarment and Suspension Verification U.S. Department of Energy – Assistance Listing No. 81.042; Grant Nos. C000082807 and NAT23001-WAPLOCAL; Grant Periods: July 2022 to June 2027, July 2023 to July 2026, and January 2024 to December 2026; Pass-through Pennsylvania Department of Community & Economic Development (DCED), Delaware Natural Resources and Environmental Control (DNREC), and Philadelphia Energy Authority (PEA). Condition: There was no evidence of contractors’ suspension or debarment status in ECA’s procurement files. Criteria: In accordance with Article V section 10, Debarment and Suspension, of ECA’s agreement with DCED: “The Grantee (ECA) may not enter into subcontracts with parties listed on the government-wide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180…, “Debarment and Suspension”. Additionally, in accordance with Appendix A, Scope of Services, section 22 of ECA’s agreement with DNREC: “It is the Vendor’s (ECA) responsibility to check all subcontractor’s for debarment prior to hire”. Cause: ECA did not retain records to evidence searching for contractors’ suspension or debarment status on sam.gov. ECA provided a report after our inquiry showing the contractors engaged were not suspended or debarred. Effect: ECA is not compliant with the Debarment and Suspension standards required by DCED, DNREC, PEA, and OMB, with respect to the awarded subcontracts. Context: ECA hires contractors to perform work for the weatherization program funded through their contracts with DCED, DNREC, and PEA. These contracts are federally funded, and certain federal debarment and suspension guidelines apply. ECA is required to confirm that contractors are not suspended and debarred for federally funded contracts. Based on our inquiries, management performs verifications to confirm that contractors engaged are not suspended or debarred from federal and/or state contracts. However, evidence of the search results was not retained in the contractors’ files. Questioned Costs: Unknown Repeat Finding: No Recommendation: ECA should ensure the search is performed before engaging contractors and retain evidence of contractors’ suspension or debarment status search results from sam.gov in the procurement files. View of responsible officials and Planned Corrective Actions: ECA Agrees with this finding and has created a new policy specifically outlining the requirements for onboarding new contractors and checking existing contractors to confirm that they are not federally debarred. ECA will review its existing contracts to confirm that no current contractors are debarred and will take further action if necessary.

Corrective Action Plan

ECA Agrees with this finding and has created a new policy specifically outlining the requirements for onboarding new contractors and checking existing contractors to confirm that they are not federally debarred. ECA will review its existing contracts to confirm that no current contractors are debarred and will take further action if necessary.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1228967 2025-002
    Material Weakness Repeat
  • 1228968 2025-003
    Material Weakness Repeat
  • 1228969 2025-004
    Material Weakness Repeat
  • 1228970 2025-002
    Material Weakness Repeat
  • 1228971 2025-003
    Material Weakness Repeat
  • 1228972 2025-004
    Material Weakness Repeat
  • 1228973 2025-002
    Material Weakness Repeat
  • 1228975 2025-004
    Material Weakness Repeat
  • 1228976 2025-002
    Material Weakness Repeat
  • 1228977 2025-004
    Material Weakness Repeat
  • 1228978 2025-002
    Material Weakness Repeat
  • 1228979 2025-004
    Material Weakness Repeat
  • 1228980 2025-002
    Material Weakness Repeat
  • 1228981 2025-004
    Material Weakness Repeat
  • 1228982 2025-002
    Material Weakness Repeat
  • 1228983 2025-004
    Material Weakness Repeat
  • 1228984 2025-002
    Material Weakness Repeat
  • 1228985 2025-004
    Material Weakness Repeat
  • 1228986 2025-002
    Material Weakness Repeat
  • 1228987 2025-004
    Material Weakness Repeat
  • 1228988 2025-002
    Material Weakness Repeat
  • 1228989 2025-004
    Material Weakness Repeat
  • 1228990 2025-002
    Material Weakness Repeat
  • 1228991 2025-004
    Material Weakness Repeat
  • 1228992 2025-002
    Material Weakness Repeat
  • 1228993 2025-004
    Material Weakness Repeat
  • 1228994 2025-002
    Material Weakness Repeat
  • 1228995 2025-004
    Material Weakness Repeat
  • 1228996 2025-005
    Material Weakness Repeat
  • 1228997 2025-002
    Material Weakness Repeat
  • 1228998 2025-004
    Material Weakness Repeat
  • 1228999 2025-002
    Material Weakness Repeat
  • 1229000 2025-004
    Material Weakness Repeat
  • 1229001 2025-002
    Material Weakness Repeat
  • 1229002 2025-004
    Material Weakness Repeat
  • 1229003 2025-002
    Material Weakness Repeat
  • 1229004 2025-004
    Material Weakness Repeat
  • 1229005 2025-002
    Material Weakness Repeat
  • 1229006 2025-004
    Material Weakness Repeat
  • 1229007 2025-002
    Material Weakness Repeat
  • 1229008 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $571,065
17.289 COMMUNITY PROJECT FUNDING/CONGRESSIONALLY DIRECTED SPENDING $487,515
14.913 HEALTHY HOMES PRODUCTION PROGRAM $382,978
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $227,000
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $223,527
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $222,651
66.815 BROWNFIELDS JOB TRAINING COOPERATIVE AGREEMENTS $144,820
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $114,699
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $113,417
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $90,844
66.616 ENVIRONMENTAL AND CLIMATE JUSTICE COMMUNITY CHANGE GRANTS PROGRAM $64,671
66.306 ENVIRONMENTAL JUSTICE COLLABORATIVE PROBLEM-SOLVING COOPERATIVE AGREEMENT PROGRAM $40,047