Finding 28441 (2022-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-12-07
Audit: 33173
Organization: Cocoon House (WA)

AI Summary

  • Core Issue: The agency failed to document procedures for verifying that entities involved in transactions were not debarred or suspended.
  • Impacted Requirements: Compliance with federal regulations (2 CFR sections 200.212, 200.318(h), 180.300) was not met in all tested transactions.
  • Recommended Follow-Up: Implement policies to ensure proper documentation is maintained for all transactions with covered entities.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number and Year: WA0000U0T042006 05/25/2021 Pass-Through Agency: Snohomish County Human Services Pass-Through Number(s): HCS-21-50-2039-077, HCS-21-50-2030-077, HCS-21-50-2032-077 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Procedures for verifying that an entity with which an organization plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded must be documented. (2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6). Condition: Procedures for verifying that an entity with which the Agency entered into covered transaction was not debarred, suspended, or otherwise excluded was not maintained for three out of three transactions tested. Questioned costs: None Context: 3 out of 3 covered transactions tested were not in compliance. Cause: Procedures were followed but not documented. Effect: Appropriate documentation was not maintained as required. Repeat Finding: N/A Recommendation: We recommend that policies and procedures are implemented that appropriate documentation is maintained when entering into transaction with covered entities as defined by 2 CFR section 180.220. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Housing & Urban Development 2022-002 Continuum of Care ? Assistance Listing No. 14.267 Recommendation: We recommend that polices and procedures are implemented and that appropriate documentation is maintained when entering into transactions with covered entities as defined by 2 CFR section 180.220.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency?s procurement policy will be updated to reflect the current federal guidelines under 2 CFR section 180.220 and 48 CFR 52.209-6 and procedures will be implmented to ensure that all covered transactions over $25,000 do not include venders that have been debarred, suspended, or proposed for debarment. Name(s) of the contact person(s) responsible for corrective action: Chris Willis, CFO Planned completion date for corrective action plan: 12/12/2022

Categories

Procurement, Suspension & Debarment Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 28440 2022-001
    Significant Deficiency
  • 28442 2022-001
    Significant Deficiency
  • 28443 2022-002
    Significant Deficiency
  • 28444 2022-001
    Significant Deficiency
  • 28445 2022-002
    Significant Deficiency
  • 604882 2022-001
    Significant Deficiency
  • 604883 2022-002
    Significant Deficiency
  • 604884 2022-001
    Significant Deficiency
  • 604885 2022-002
    Significant Deficiency
  • 604886 2022-001
    Significant Deficiency
  • 604887 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Emergency Rental Assistance Program $3.19M
14.267 Continuum of Care Program $463,689
14.239 Home Investment Partnerships Program $400,000
17.259 Wia Youth Activities $213,958
14.231 Emergency Solutions Grant Program $206,538
16.320 Services for Trafficking Victims $142,611
93.623 Basic Center Grant $109,652
21.027 Coronavirus State and Local Fiscal Recovery Funds $98,120
14.218 Community Development Block Grants/entitlement Grants $12,693
21.019 Coronavirus Relief Fund $7,067
93.550 Transitional Living for Homeless Youth $3,024
93.557 Education and Prevention Grants to Reduce Sexual Abuse of Runaway, Homeless and Street Youth $2,803