Finding 15785 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-27

AI Summary

  • Core Issue: Lack of a policy for conflicts of interest and procurement procedures to check vendor suspension or debarment status.
  • Impacted Requirements: Non-compliance with OMB guidance on contracting with suspended or debarred parties.
  • Recommended Follow-up: Develop and implement clear procurement policies and provide training to staff on compliance requirements.

Finding Text

Criteria Per OMB guidance, non-federal entities are prohibited from contracting with parties that are suspended or debarred, or whose principals are suspended or debarred. The guidance also requires the entities to follow documented procurement procedures. Condition There is no policy in place for conflicts of interest, as well as procurement procedures to determine whether vendors are suspended or debarred. Context Per our review of vendors over the applicable threshold, there was no documentation of having been reviewed for procurement, suspension or debarment. Cause Staff were not aware of the specific compliance requirements and procedures for procurement, suspension and debarment status. Effect Purchases may occur that do not follow the policy, and contracts to vendors that had been suspended or debarred could be awarded and not detected.

Corrective Action Plan

Auditor's Recommendations The Organization should adopt Procurement Policy including a section concerning Federal Awards including a section on verifying the status of each potential sub-recipient before disbursement of Federal funds. Executive Director, Christian Wells, will review and approve this policy and UWTC Board of Directors will approve this policy. Response: Finance Director, Richele Center, will update the United Way of Thurston's set of finance policies with a procurement policy including a section concerning federal awards. Sub-Recipients will be verified before disbursement of Federal funds and sample language prepared for inclusion in contracts with sub-recipients that details this requirement. The new PP will include the following language. Budget Managers who allocate Federal funding will be required to read and sign a document stating that they are aware of the Federal provisions requiring contract language around Suspension and Debarment, ensure that language exists in sub-recipient contracts, confirm with Finance Director that the sub-recipients have been checked prior to fund distribution using the SAM.gov registration. Finance Director will develop a process for checking sub-recipient debarment status and include language outlining the program in the PP. Finance Director will be responsible for working with the Budget Manager to verify all sub-recipients have been checked for debarment prior to disbursing future Federal funding. Timing of remediation completion: Finance Director, Richele Center, will complete by March 23, 2023.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 15786 2022-002
    Significant Deficiency
  • 592227 2022-001
    Significant Deficiency
  • 592228 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $926,620
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $166,802
94.002 Retired and Senior Volunteer Program $65,316
94.013 Volunteers in Service to America $25,000