Finding 1238528 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: The Organization lacks formal procedures to verify if subrecipients, contractors, and vendors are suspended or debarred from federal programs.
  • Impacted Requirements: This violates 2 CFR Part 180.300, which mandates vetting of parties before agreements or federal fund expenditures.
  • Recommended Follow-Up: Management should implement documented procedures for verification and retain evidence of checks against SAM.gov to ensure compliance.

Finding Text

Criteria: In accordance with 2 CFR Part 180.300, non-federal entities are prohibited from entering into covered transactions with parties that are suspended or debarred from participation in federal programs. Internal controls should provide reasonable assurance that applicable subrecipients, contractors, and vendors are appropriately vetted before agreements are executed or federal funds are expended. Condition: The Organization had not established or documented procedures to verify whether any applicable subrecipients, contractors, and vendors were suspended or debarred. Management was unable to provide evidence that searches of SAM.gov or other permitted verification methods had been performed before entering into agreements or making federally funded payments. Cause: The Organization had not implemented formal policies requiring suspension and debarment verification or retention of supporting documentation. As a result, verification was performed informally and evidence of review was not retained. Effect: Testing did not identify any parties that were suspended or debarred, however, the absence of documented controls increases the risk that the Organization could enter into federally funded transactions with prohibited parties without timely detection. Questioned Costs: None noted Repeat Finding: No Recommendation: We recommend that management establish procedures to verify and document the suspension and debarment status of applicable subrecipients, contractors, and vendors before entering into agreements or expending federal funds. Evidence of SAM.gov searches or other permitted verification methods should be retained to demonstrate compliance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding; see corrective action plan.

Corrective Action Plan

All Chicago will: • Develop and formally adopt procedures requiring a suspension and debarment check via SAM.gov or an alternative verification method for all subrecipients, contractors, and significant vendors on federal awards. • Centralize documentation storage where suspension and debarment information is archived. • Conduct mandatory training for all staff involved in this compliance requirement. • Complete a retroactive assessment on active subrecipients. o Note: the retroactive assessment is currently underway.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1238526 2025-003
    Material Weakness Repeat
  • 1238527 2025-004
    Material Weakness Repeat
  • 1238529 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $11.67M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $1.90M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.37M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $301,752