FAC Explorer

Finding 31931 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-22
Audit: 27732
Organization: Domestic Violence Program INC (TN)
Auditor: Jobe Hastings & Associates

AI Summary

  • Core Issue: The Organization failed to verify that a vendor was not suspended or debarred before requesting reimbursement for a grant transaction.
  • Impacted Requirements: Compliance with 2 CFR Part 180, which mandates that non-federal entities ensure parties to covered transactions are not excluded or disqualified.
  • Recommended Follow-Up: Implement internal controls, create a policy for verifying vendor status, and train staff on the importance of checking for debarment before awarding contracts.

Finding Text

2022-003 - Suspension and Debarment - Condition and context: We tested one covered transaction that the Organization requested reimbursement for under a grant program. We did not find evidence that the Organization performed procedures to ensure that a vendor that had not been suspended or debarred for a grant expenditure that was a covered transaction. Criteria: Suspension and debarment requirements in 2 CFR Part 180 require a non-federal entity to ensure that any person that is a party to a covered transaction entered into by the non-federal entity is not excluded or disqualified. A non-federal entity has three options for performing this verification: 1) obtaining a certification from the person; 2) checking the System for Award Management (SAM) Exclusions (https://www.sam.gov/SAM/); or 3) adding language to the contract or subaward with the person. Cause of Condition: Management was not aware of the requirements. Effect: Federal funds could be made to a vendor that has been suspended or debarred. Recommendation: For covered transactions, the Organization should verify that a vendor has not been suspended or debarred by either: 1) obtaining a certification from the person; 2) checking the System for Award Management (SAM) Exclusions (https://www.sam.gov/SAM/); or 3) adding language to the contract or subaward with the person. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with this finding and will implement the following: ? Develop/design internal control to provide reasonable assurances that Federal funds are not made to a vendor that has been suspended or debarred. ? Creation of policy to ensure that contracts are not awarded to contractors or individuals on the List of Parties Excluded from Federal Procurement and Non-procurement Programs. ? Perform a System of Award Management of potential contractors or individuals and print results for vendor?s file. ? Not award or permit any award at any level to any party which is debarred or suspended. ? Train leadership and grants manager on the importance of verification of debarment and suspension before any contracts are entered into by the agency.

Corrective Action Plan

Finding 2022-003 - Suspension and Debarment Recommendation: For covered transactions, the Organization should verify that a vendor has not been suspended or debarred by one of the three approved methods. Background: Management was not aware of the requirements. Responsible Person: Ericka Downing Corrective Action: The Organization agrees with this finding and will implement the following: ? Develop/design internal control to provide reasonable assurances that Federal funds are not made to a vendor that has been suspended or debarred. ? Creation of policy to ensure that contracts are not awarded to contractors or individuals on the List of Parties Excluded from Federal Procurement and Non-procurement Programs. ? Perform a System of Award Management of potential contractors or individuals and print results for vendor?s file. ? Not award or permit any award at any level to any party which is debarred or suspended. ? Train leadership and grants manager on the importance of verification of debarment and suspension before any contracts are entered into by the agency. Completion date: March 31, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 31930 2022-002
    Significant Deficiency
  • 31932 2022-002
    Significant Deficiency
  • 31933 2022-003
    Significant Deficiency
  • 31934 2022-002
    Significant Deficiency
  • 31935 2022-003
    Significant Deficiency
  • 31936 2022-002
    Significant Deficiency
  • 608372 2022-002
    Significant Deficiency
  • 608373 2022-003
    Significant Deficiency
  • 608374 2022-002
    Significant Deficiency
  • 608375 2022-003
    Significant Deficiency
  • 608376 2022-002
    Significant Deficiency
  • 608377 2022-003
    Significant Deficiency
  • 608378 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
16.575 Crime Victim Assistance $332,175
14.231 Covid-19 Emergency Solutions Grant Program $265,505
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $248,510
16.582 Crime Victim Assistance/discretionary Grants $27,366
16.736 Transitional Housing Assistance for Victims of Domestic Violence, Dating Violence, Stalking, Or Sexual Assault $25,980
14.231 Emergency Solutions Grant Program $22,151
14.218 Community Development Block Grants/entitlement Grants $22,000
14.267 Covid-19 Continuum of Care Program $21,145
97.024 Emergency Food and Shelter National Board Program $7,500