Finding 23223 (2022-002)

Significant Deficiency

Requirement

Questioned Costs

Year

2022

Accepted

2023-09-27

Audit: 26672

Organization: Aha Punana Leo, Inc. (HI)

Auditor: Davis Farr LLP

AI Summary

Core Issue: `Aha Punana Leo failed to keep proof that contracted parties were not suspended or debarred, violating federal requirements.
Impacted Requirements: Non-federal entities must verify and document the status of contractors to ensure compliance with 2 CFR section 180 for transactions over $25,000.
Recommended Follow-Up: Implement a system to retain verification evidence for all contracts exceeding $25,000 to prevent future compliance issues.

Finding Text

2022-002: Suspension and Debarment Information on the Federal Program: Assistance Listing Number 84.362A Native Hawaiian Education Program Criteria: Non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred when the transaction is expected to equal or exceed $25,000 as specified in 2 CFR section 180. Condition and Context: `Aha Punana Leo did not retain evidence of verification that the parties contracted were not suspended, debarred, or otherwise excluded from doing business under the grant. Cause: While `Aha Punana Leo has a policy requiring verification of suspension and debarment during the procurement process, the Organization did not retain evidence that the verification was performed. Effect or Potential Effect: Doing business with an entity that is suspended or debarred. Questioned Costs: $0 Recommendation: We recommend the Organization retain evidence of the verification of suspension or debarment prior to contracting with an entity that is expected to be paid $25,000 or more.

Corrective Action Plan

Corrective Action Plan: This plan will address and be implemented to remedy the Finding 2022-002: Suspension and Debarment Timeline: The Corrective Action Plan was initiated on October 1, 2023. The transition is expected to be completed by October 25, 2023 with ongoing support. Plan and Status of Corrective Action: 1. Beginning October 1, 2023 ?Aha Punana Leo is adding the necessary steps to enhance our Standard Operating Procedure to require storing documentation and evidence to verify that contracted or subaward entities are not suspended, debarred or otherwise excluded from doing business under our grants. We are accepting all reccomendations from our auditors. The additional verification and retention steps will be built into the procurement process to store the evidence in digital files. We will be hosting additional training with our staff to ensure the SOP?s are followed. the organization has reorganized our Fiscal Department and redistributed job duties.

Other Findings in this Audit

23224 2022-002

Significant Deficiency
599665 2022-002

Significant Deficiency
599666 2022-002

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
84.362	Native Hawaiian Education	$861,870
93.357	Promote the Survival and Continuing Vitality of Native American Languages	$296,489
10.558	Child and Adult Care Food Program	$158,824