Finding 1237993 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-29
Audit: 412813
Auditor: BROWN PLUS

AI Summary

  • Core Issue: The Institute lacks formal written policies for verifying suspension and debarment, risking compliance with federal program requirements.
  • Impacted Requirements: Failure to follow procurement procedures as outlined in 2 CFR Part 200 could lead to contracts with excluded parties.
  • Recommended Follow-Up: Develop and implement written procurement policies that include verification procedures and assign responsibility for compliance checks.

Finding Text

Finding number 2025-001, significant deficiency in internal controls over major federal programs – suspension and debarment verification not performed Federal Agency: U.S. Department of Justice Pass-through entity: Pennsylvania Commission on Crime and Delinquency Federal Program: Crime Victim Assistance, ALN 16.575 Criteria: Under the Uniform Guidance compliance requirement for Procurement and Suspension and Debarment, recipients must establish and follow written procurement procedures that conform to applicable federal statutes and the requirements identified in 2 CFR Part 200. Contracts and subawards under covered transactions must not be made with parties listed in the General Services Administration's System for Award Management (SAM) Exclusions. Condition: The Institute does not have formal written policies or procedures addressing suspension and debarment requirements applicable to covered transactions under federal awards. Specifically, the Institute's procurement policies do not require personnel to: • Determine whether a transaction is a covered transaction subject to suspension and debarment requirements; • Verify vendors or contractors against SAM Exclusions prior to entering into covered transactions; • Retain documentation of SAM Exclusions searches or other allowable verification procedures in the procurement or grant file; and • Assign responsibility for performing and reviewing suspension and debarment verification. Although management indicated that staff generally use vendors known to the Institute, no formal control has been established requiring suspension and debarment verification before covered transactions are executed. Cause: The Institute does not have a procurement policy that incorporates the suspension and debarment compliance requirements applicable to federal awards. Effect: Without formal written suspension and debarment procedures, the Institute may enter into covered transactions with parties that are suspended, debarred or otherwise excluded from participation in federal programs. Such transactions could result in noncompliance with federal award requirements and may expose the Institute to disallowed costs, repayment obligations or other remedies imposed by the federal awarding agency or pass-through entity. Questioned Costs: N/A Recommendation: Management should develop written procurement policies and procedures that incorporate suspension and debarment requirements for federal award transactions. At a minimum, the revised procedures should: • Define covered transactions subject to suspension and debarment verification requirements; • Require SAM Exclusions verification prior to entering into covered transactions with vendors or contractors; • Require documentation retention, such as screenshots, search results, vendor certifications or contract clauses, as applicable; • Assign responsibility for performing and reviewing suspension and debarment verification; • Incorporate the procedures into procurement approvals, grant checklists or contract review workflows; and • Provide periodic training to personnel involved in federal procurement and grant administration. Implementation of these procedures will help ensure that contracts and subawards under covered transactions are not made with parties that are suspended, debarred or otherwise excluded from federal programs. Views of Responsible Officials: Management concurs with this finding and will develop written procurement policies incorporating suspension and debarment procedures for covered transactions under federal awards. The procedures will require documented SAM Exclusions verification prior to approving covered transactions and will identify personnel responsible for performing and reviewing the verification.

Corrective Action Plan

Audit Finding: During the 2025 audit, PDAI was notified that it is a requirement to document and maintain SAM.gov vendor eligibility verifications for procurement transactions that exceed $25,000.00 per contracted year and are charged to federal programs or any sub awardees regardless of amount. Views of officials responsible: We acknowledge that internal control should be strengthened by reviewing the current Uniform Guidance Requirements - all vendors at or above the designated threshold (2025 was $25,000.00/contracted year) and all sub awardees must be verified thorugh the System for Award Management website (SAM.gov) and a screenshot/printed screen must be kept for documentation. Corrective Action: Beginning in Quarter 4 of 2026, routine checks will be completed for any PDAI vendors that are contracted to be paid over the threshold designated in the Uniform Guidance Requirements and all sub awardees before any initial payments are made and then concurrently on a quarterly basis. This threshold will be reviewed on a yearly basis to stay up to date with the Uniform Guidance Requirements. Management has designated a specific preparer and reviewer while requiring sign offs as a secondary check and balance. Responsible Parties: Jennell Miller, Accounting Manager Tina Fornstrom, Business Manager Implementation Date: October 1, 2026 (start of Q4 2026) Ongoing Monitoring: The Accounting Manager and Business Manager will work together ensuring guidelines are up to date, regular checks are completed and the opposite party will sign off after reviewing the documentation.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1237992 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $476,762
16.575 CRIME VICTIM ASSISTANCE $230,061
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $212,017
16.609 PROJECT SAFE NEIGHBORHOODS $8,027
20.614 NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION (NHTSA) DISCRETIONARY SAFETY GRANTS AND COOPERATIVE AGREEMENTS $8,000