Finding 1240750 (2024-004)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-10-21
Audit: 415137
Organization: NATIONAL WIC ASSOCIATION (DC)

AI Summary

  • Core Issue: The Association failed to consistently perform and document suspension and debarment checks for vendors before entering into contracts, increasing the risk of noncompliance with Federal regulations.
  • Impacted Requirements: This finding violates 2 CFR §200.303 and 2 CFR part 180, which mandate effective internal controls and compliance with suspension and debarment regulations.
  • Recommended Follow-Up: Implement internal controls for mandatory suspension and debarment checks before contracts, retain evidence of checks, and establish a policy for annual screenings of existing vendors.

Finding Text

Finding 2024-004: Suspension and Debarment Information on the Federal Programs: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing No. 10.557 Federal Agency: U.S. Department of Agriculture Federal Award Identification Number: WIC-ARPA-MIS-STRAT-24 Federal Award Year: Year ended December 31, 2024 Compliance Requirement: Procurement - Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other MattersCriteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): As stated in 2 CFR §200.303, the non-Federal entity (i.e. the Association) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to 2 CFR §200.214, the non-Federal entity is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: During our audit, we noted that the Association did not consistently perform or retain evidence of suspension and debarment checks through SAM.gov for applicable vendors, contractors, or consultants before entering into covered transactions. Cause: Management did not have effective internal controls in place to ensure that suspension and debarment checks were consistently performed and documented before entering into applicable contracts or other covered transactions. Effect or Potential Effect: The Association is exposed to an increased risk of entering into transactions with vendors, contractors, or consultants that are suspended, debarred, or otherwise excluded from participation in Federal programs. Such noncompliance could result in disallowed costs or other remedies available to the Federal awarding agency. Questioned Costs: None. Although the Association did not retain sufficient documentation to demonstrate that suspension and debarment checks were performed before entering into applicable transactions, we performed procedures to search the selected vendors, contractors, and consultants tested through SAM.gov. Based on those procedures, none of the selected parties tested were identified as suspended, debarred, or otherwise excluded from participation in Federal programs. Accordingly, no questioned costs were identified. Context: We selected 2 of 2 applicable vendor, contractor, or consultant agreements for suspension and debarment testing. The items selected were intended to be representative of the population tested. For 2 of 2 items tested, the Association did not provide documentation that a SAM.gov suspension and debarment check was performed before entering into the applicable transaction. Based on the nature of the control deficiency, the matter is considered systemic. Identification as a Repeat Finding, if Applicable: Not Applicable. Recommendation: We recommend that the Association implement internal controls requiring suspension and debarment screening before entering into any applicable contract or covered transaction funded by Federal awards. Evidence of the SAM.gov search should be retained in the vendor or contract file. We also recommend that the Association formalize a policy requiring periodic, at least annual, screening of existing vendors, contractors, and consultants that are expected to continue providing goods or services under Federal awards.

Corrective Action Plan

Views of Responsible Officials: The Association acknowledges the observation regarding the timing of SAM verification for vendors associated with the Federal award. The vendors identified in the finding were not recruited and selected by the Association in a formal process, but as longstanding partners of the Association, they collaborated on the submission, which defined project roles. However, the Association recognizes that SAM verification should have been completed and documented prior to vendor engagement, regardless of the vendor selection process. To address this matter, the Association has updated its procurement and grant administration procedures to require SAM verification before executing agreements or authorizing work under any Federal award. Verification will be documented and retained within the procurement file, and a standardized pre-award compliance checklist has been implemented to ensure all applicable Federal requirements are completed before services begin. The Association will also perform periodic reviews of procurement files to monitor ongoing compliance with these procedures.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1240749 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $852,460