Finding 1239144 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414002
Organization: CHURCH OF THE NEW COVENANT (PA)
Auditor: GUTHRIE & CO PC

AI Summary

  • Core Issue: The Organization did not properly document the rationale for choosing a non-competitive procurement method, violating federal compliance standards.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and 2 CFR 200.318 regarding effective internal controls and documented procurement policies.
  • Recommended Follow-Up: Implement a system to ensure all procurement decisions are documented, including price comparisons and rationale, to strengthen compliance controls.

Finding Text

Finding 2025-001 –Procurement , Suspension & Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to the procurement standards in sections 200.317 through 200.327. These standards generally require recipients to maintain records sufficient to detail the history of procurement, including the rationale for the procurement method, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Testing of the federal program identified the following: • The Organization failed to document price comparisons including the rationale or circumstances leading up to the selection of the non-competitive sole source procurement. The Organization did follow through with the suspension and debarment check of the contracted vendor. Cause: The Organization lacked adequate documentation of procurement decisions being reached during the initial project funding phase. Effect/Potential Effect: Ineffective controls over this area of compliance could result in a reasonable possibility the Organization would be noncompliant with the compliance requirements outlined above. Questioned Costs: None reported. Context / Sampling: A statistical sample of 1 out of 3 vendors selected for testing.

Corrective Action Plan

Regarding Finding 2025-001, pertaining to procurement, the Pennsylvania Broadband Development Authority has determined that the vendor in question was a project manager and did not provide general contracting services. As such, the rules regarding procurement were inapplicable. Please see the attached email from the Pennsylvania Broadband Development Authority. Related to any corrective action regarding this finding, pertaining to any future federal monies, Church of the New Covenant commits to using documented procurement policies which conform to the procurement standards in 2 CFR 200.317 through 200.327. Church of the New Covenant will in the future maintain records which sufficiently detail the history of procurement, including the rationale for procurement method, selection of contract type, contractor selection or rejection, and the basis for contract price. In the future, a staff person will be assigned the responsibility for the implementation of supervisory review procedures, for the review and updating of the procurement policy and procedures, and for the development of a standardized procurement file checklist.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1239145 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $1.97M