Finding 31526 (2022-002)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-02-14
Audit: 35926
Organization: Utah Food Bank (UT)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The Organization lacks effective internal controls over procurement policies, failing to meet federal requirements for monitoring contractor eligibility.
  • Impacted Requirements: Noncompliance with 2 CFR 200.318-200.325 and 31 CFR 19.300, specifically regarding contractor suspension and debarment documentation.
  • Recommended Follow-Up: Implement stronger internal controls to ensure procurement policies are comprehensive and compliant with federal regulations.

Finding Text

2022-002 Department of the Treasury, Passed through Utah Department of Workforce Services Federal Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension, and Debarment Material Weakness in Internal Control 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. Condition: The Organization?s written procurement policies did not include all of the elements required by the Code of Federal Regulations 2 CFR 200.318-200.325, including monitoring that contractors are not suspended, debarred, or otherwise excluded pursuant to 31 CFR 19.300 and retaining documentation thereof. In addition, two construction contracts did not include all of the provisions required by Appendix II of 2 CFR Part 200. Cause: The Organization did not have internal controls in place to document procurement policies, to document monitoring contractors for suspension and debarment, or to ensure contracts with contractors included the required elements. Effect: The risk is increased that a procurement noncompliance could occur. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used. Sample size was 4 of 10 procurement transactions above the micro-purchase threshold and included $551,791 of federal awards. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the Organization implement additional internal controls over procurement policies and procedures. Views of Responsible Officials: Management agrees with this finding.

Corrective Action Plan

Finding: 2022-02 Finding Summary: Utah Food Bank verified that contractors were not suspended, debarred, or otherwise excluded from System Award Management (?SAM?), but did not document the procedure and did not retain documentation of this action. Responsible Individuals: Jennifer Pratt, Chief Financial Officer Corrective Action Plan: Utah Food Bank will continue to enhance internal controls over written procurement policies and monitoring vendors to ensure its compliance with the Code of Federal Regulations, including keeping documentation of SAM compliance on each vendor before the work starts and upon each disbursement. Anticipated Completion Date: February 24, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 31525 2022-001
    Material Weakness
  • 607967 2022-001
    Material Weakness
  • 607968 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $17.31M
21.027 Coronavirus State and Local Fiscal Recovery Funds $8.72M
10.568 Emergency Food Assistance Program (administrative Costs) $2.11M
10.565 Commodity Supplemental Food Program (food Commodities) $1.60M
10.558 Child and Adult Care Food Program $905,191
10.559 Summer Food Service Program for Children $895,066
10.565 Commodity Supplemental Food Program $118,583