Finding Text
Corporation for National and Community Service Federal Financial Assistance Listing #94.012, 22BIICA001 10/1/2022 – 9/30/2025, 23BIACA001 10/1/2023 – 9/30/2026, 23BIFNY001 10/1/2023 – 9/30/2026 Americorps September 11th National Day of Service and Remembrance Grants Procurement, Suspension and Debarment Material Weakness in Internal Controls over Compliance and Noncompliance 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 conditions of the federal award. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.327 which also requires documentation to be retained to detail the history of procurements. Condition: The Organization’s procurement policy is missing required provisions in accordance with 2 CFR 200.318. For each of the 3 vendors selected for testing there was no documentation retained to support the rationale for the method of procurement. Additionally, the Organization did not retain supporting documentation to substantiate whether consideration was taken whether the vendor was suspended or debarred from doing business with the federal government prior to entering the covered transaction for each of the 3 vendors selected for testing. Cause: There was a lapse in oversight of the internal control process ensuring documentation was retained supporting the Organization’s procurement, suspension and debarment process. Additionally, the Organization did not cross reference procurement policy with 2 CFR 200.318 through 200.327 ensuring minimum required provisions were included within. Effect: Without retaining documentation to support procurement, suspension and debarment rationale, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 3 vendors out of 9 vendors were selected for testing. Repeat Finding from Prior Year: Yes, prior year finding 2024-003 Recommendation: We recommend management to review internal control procedures ensuring support is retained to substantiate procurement, suspension and debarment was considered prior to entering the transaction. We recommend management review 2 CFR 200.318 through 200.327 and revise the Organization’s procurement policy to include all minimum required provisions. Views of Responsible Officials: Management is in agreement.