Finding 1238589 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 413441
Organization: Connections to Success (MO)

AI Summary

  • Core Issue: The organization failed to document vendor verification for suspension and debarment, impacting compliance with federal regulations.
  • Impacted Requirements: Non-compliance with Uniform Grant Guidance (200.214) and 2 CFR part 180, which mandates verification before awarding federal funds.
  • Recommended Follow-Up: Implement procedures to verify vendor status prior to fund disbursement and maintain documentation of these verifications.

Finding Text

2025-001 Suspension and Debarment Federal Agency: U.S. Department of Labor Federal Program Title: Reintegration of Ex-Offenders Assistance Listing No. 17.270 Award Periods: July 1, 2023 – December 31, 2026 Type of Finding: • Material Weakness in Internal Control Over Compliance – Suspension and Debarment • Other Matter Questioned Costs: None Condition: During our testing of 5 suspension and debarment samples, CLA noted no documentation was maintained related to verifying vendors were not suspended or debarred for any of the 5 samples (100%) prior to disbursement. The statement of work outlines use of all of these vendors, but inclusion in the description in the statement of work of entities does not preclude the requirement to test for suspension and debarment issues. Though verification was done at the time of the audit, no support could be provided to show the control took place prior to use of the vendor. Criteria: Uniform Grant Guidance (200.214) states the non-Federal entity is subject to the debarment and suspension regulations as 2 CFR part 180, requiring no federal funds be awarded to parties that are suspended, debarred, or otherwise excluded from federal programs. Context: The Organization did not maintain adequate documentation related to verification that vendors were not suspended or debarred prior to use of such vendor for the 5 items sampled. The sampling methodology used is not, and is not intended to be statistically valid. Effect: Failure to properly approve contractors and maintain documentation may result in federal funds being charged to the grant for activities related to suspended or debarred vendors. Cause: The Organization did not have effective internal controls over compliance in place to ensure documentation of suspension and debarment procedures were followed prior to use of the vendor. Repeat Finding: The finding is a repeat of the prior year finding number 2024-001. Recommendation: We recommend that the Organization implement procedures to verify vendors against applicable suspension and debarment requirements prior to the disbursement of funds and retain documentation evidencing the verification performed. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Type of Finding: Material Weakness in Internal Control Over Compliance – Suspension and Debarment; Other Matter Recommendation: We recommend that the Organization implement procedures to verify vendors against applicable suspension and debarment requirements prior to the disbursement of funds and retain documentation evidencing the verification performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding is a repeat of prior-year finding 2024-001. The vendor selections identified in the auditor's test sample were engaged prior to November 2025, before the Organization's enhanced verification procedures were implemented. Building on the corrective action plan submitted for fiscal year 2024, the Organization has taken the following corrective actions: ● Beginning in November 2025, the Organization has required completion of a standardized Vendor Eligibility & Compliance Review Form, including documented SAM.gov verification, before engaging any vendor that will be paid in whole or in part with federal funds and before any federal funds are disbursed to that vendor. This procedure continues to be used for all applicable vendors. ● The Organization's Procurement and Vendor Management Policy was formally updated, effective March 3, 2026, as part of the corrective action plan submitted to and approved by the U.S. Department of Labor. The policy explicitly requires suspension and debarment verification, in accordance with 2 CFR 200.214 and 2 CFR Part 180, before a vendor is engaged or paid with federal funds, memorializing the procedures in practice since November 2025. ● All staff involved in procurement have been trained on the updated policy and documentation requirements. ● The Operations Director performs quarterly monitoring of vendor files to confirm that vendor verification procedures are consistently followed and documented. This monitoring has been implemented and is continuing. These controls have been in practice since November 2025 and were formally documented in policy effective March 3, 2026. They continue to be monitored on an ongoing basis to prevent recurrence. The vendor selections cited in the current year finding predate the November 2025 implementation. Name(s) of contact person(s) responsible for corrective action: Cory Finley, Operations Director, with oversight by Brandi Jahnke, Chief Executive Officer Planned completion date for corrective action plan: Implemented in practice as of November 2025 and formalized in written policy effective March 3, 2026. Quarterly monitoring by the Operations Director is ongoing.

Categories

Procurement, Suspension & Debarment Material Weakness

Other Findings in this Audit

  • 1238590 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.270 Reintegration of Ex-Offenders $882,326
21.027 COVID 19 - Office of Violence Prevention- State and Local Fiscal Recovery Fund $370,894
93.558 Temporary Assistance for Needy Families (TANF) Youth and Family Stability Program $96,377
16.812 Second Chance Act Community-Based Reentry Program $92,200
17.805 Homeless Veterans Reintegration Program $49,065
93.558 Temporary Assistance for Needy Families (TANF) Healthy: Marriage Promotion and Responsible Fatherhood Initiatives $25,607