Finding 1239209 (2025-003)

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

AI Summary

  • Core Issue: The Organization lacks adequate internal controls to verify that vendors are not suspended or debarred before contract signing.
  • Impacted Requirements: Compliance with 2 CFR Part 200 regarding procurement, suspension, and debarment is not being met.
  • Recommended Follow-Up: Implement internal controls and maintain documentation to ensure compliance with vendor verification requirements.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: Environmental Quality Incentives Program Assistance Listing Number: 10.912 Federal Award Identification Number and Year: NR243A750011G009 - 2024 Award Period: 9/1/24-9/29/29 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance Requirement: Procurement, Suspension and Debarment. Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Organization should have policies and procedures in place to following in relation to procurement, suspension, and debarment. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned costs: None Context: During our testing, it was noted that the Organization did not maintain documentation over verification the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration prior to entering into a signed contract. This was a finding in the prior year audit and a plan was put into place in September 2025 to address the issue but was not implemented for part of the period under audit. Cause: Due to the timing of when the formal procedures were put in place. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: Repeat Finding 2024-004 Recommendation: Internal controls should be implemented to make sure procurement methods are properly followed and documentation is maintained. We recommend the Organization develop and implement controls to ensure compliance with suspension and debarment requirements and keep an electronic or manual file indicating that such review was done to verify that they are following compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Environmental Quality Incentives Program – Assistance Listing No. 10.912 Recommendation: Internal controls should be implemented to make sure procurement methods are properly followed and documentation is maintained. We recommend the Organization development and implement controls to ensure compliance with suspension and debarment requirements and keep an electronic or manual file indicating that such review was done to verify that they are following compliance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit Status of corrective action: This finding recurred because the controls below were implemented in October 2025 and were not in place for the full 2025 audit period. We expect it to be resolved in the 2026 audit. Procurement: In October 2025, the Organization updated its procurement policy to follow the Uniform Guidance. Each federally funded purchase has a procurement file documenting the method used and the basis for vendor selection and price, reviewed by someone other than the preparer. Suspension and debarment: Before any federally funded contract is signed, the Grants Manager verifies the vendor in SAM.gov and saves a dated screenshot showing the search, results, and reviewer name in the project folder. Name(s) of the contact person(s) responsible for corrective action: Jill Matchett, Grants Manager through June 2026, Lori Hall, Grants Manager June 2026 - present Planned completion date for corrective action plan: Implemented October 2025; expected to be resolved in the audit for the year ending December 31, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1239207 2025-001
    Material Weakness Repeat
  • 1239208 2025-002
    Material Weakness Repeat
  • 1239210 2025-004
    Material Weakness Repeat
  • 1239211 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.912 Environmental Quality Incentives Program $725,547
10.937 Partnerships for Climate-Smart Commodities $529,243
10.311 Beginning Farmers and Ranchers Development Program $110,252
10.902 Soil and Water Conservation $80,549
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $33,807
10.164 Wholesale Farmers and Alternative Market Development $16,142