Finding 1235984 (2025-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-22

AI Summary

  • Core Issue: All four tested vendor transactions lacked documentation for suspension and debarment verification.
  • Impacted Requirements: Compliance with 2 CFR 200.214 and 2 CFR 180, which mandate verification of vendor status to avoid contracting with suspended or debarred parties.
  • Recommended Follow-Up: Establish a formal procedure for verifying and documenting vendor suspension and debarment status, including retaining evidence and implementing review controls before contract approval or payment.

Finding Text

Suspension and Debarment Federal Agency: Department of Housing and Urban Development Federal Program: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Assistance Listing Number: 14.251 Award Period: February 5, 2024 – August 31, 2031 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Per 2 CFR 200.214 and 2 CFR 180, nonfederal entities must not contract with or make awards to parties that are suspended or debarred and must verify the status of covered parties (e.g., through SAM.gov) and maintain documentation of that verification. Condition: Of four procurement transactions tested, four lacked documentation evidencing suspension and debarment verification. Questioned costs: None. Context: We tested 4 vendor transactions within the major program; none included documentation evidencing suspension and debarment verification. Cause: The deficiency appears to be due to the absence of a formal process and/or review control to document suspension and debarment verification for vendors prior to contract execution or payment. Effect: Failure to document suspension and debarment checks increases the risk of contracting with ineligible vendors and may result in noncompliance and questioned costs. Repeat finding: No. Recommendation: We recommend the Organization implement a formal procedure to verify and document suspension and debarment status (e.g., SAM.gov checks) for all covered transactions, including retaining evidence of the verification and incorporating a review control prior to payment or contract approval. View of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Economic Development Initiative, Community Project Funding, and Miscellaneous Grants – Assistance Listing No. 14.251 Recommendation: We recommend the Organization implement a formal procedure to verify and document suspension and debarment status (e.g., SAM.gov checks) for all covered transactions, including retaining evidence of the verification and incorporating a review control prior to payment or contract approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented procedures to verify suspension and debarment status for covered transactions, including documenting SAM.gov reviews and retaining evidence of verification prior to contract approval or payment processing. Name(s) of the contact person(s) responsible for corrective action: Jeff Fournier, Finance Director Planned completion date for corrective action plan: June 30, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1235978 2025-006
    Material Weakness Repeat
  • 1235979 2025-003
    Material Weakness Repeat
  • 1235980 2025-003
    Material Weakness Repeat
  • 1235981 2025-003
    Material Weakness Repeat
  • 1235982 2025-004
    Material Weakness Repeat
  • 1235983 2025-004
    Material Weakness Repeat
  • 1235985 2025-005
    Material Weakness Repeat
  • 1235986 2025-005
    Material Weakness Repeat
  • 1235987 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.761 WATER AND WASTE TECHNICAL ASSISTANCE AND TRAINING GRANTS $322,562
10.771 RURAL COOPERATIVE DEVELOPMENT GRANTS $204,000
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $184,037
10.871 SOCIALLY-DISADVANTAGED GROUPS GRANT $162,605
10.872 HEALTHY FOOD FINANCING INITIATIVE $117,344
10.446 RURAL COMMUNITY DEVELOPMENT INITIATIVE $105,061
14.024 COMMUNITY DEVELOPMENT BLOCK GRANT- PRICE COMPETITION $48,309
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $45,640
10.164 WHOLESALE FARMERS AND ALTERNATIVE MARKET DEVELOPMENT $14,463
10.351 RURAL BUSINESS DEVELOPMENT GRANT $12,665
66.202 CONGRESSIONALLY MANDATED PROJECTS $433