FAC Explorer

Finding 33029 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-08-27
Audit: 29790
Organization: Village Exchange Center (CO)
Auditor: Watson Coon Ryan LLC

AI Summary

  • Core Issue: The organization lacks formal procurement policies, leading to significant deficiencies in compliance with federal guidelines.
  • Impacted Requirements: Non-compliance with UG 200.318, 200.319, and 200.320 regarding procurement standards and competition.
  • Recommended Follow-Up: Implement a comprehensive procurement policy to ensure proper documentation and oversight for all procurement activities.

Finding Text

Finding 2022-003 ? Procurement Information on the Federal Program: Assistance Listing Number 21.027 - COVID-19: American Rescue Plan Act of 2021 - Coronavirus State and Local Fiscal Recovery Funds, Pass through Entity ? Arapahoe County. Compliance requirements: Procurement Type of Finding: Significant deficiency in Internal Control over Compliance, Non compliance Criteria: The Organization is required to have documented procurement policies and procedures which comply with the compliance requirement: UG ?200.318 general procurement standards, UG ?200.319 competition, and ?200.320 methods of procurement to be followed. Condition: The Organization does not have formal policies and procedures over procurement to ensure controls and oversight are in place to ensure procurement compliance requirements are met. Cause: Lack of a formal policy and procedure over procurement. Effect: Possible payment of federal funds to vendors that did not properly go through the required procurement steps in accordance with Uniform Guidance. Questioned Costs: $25,000 Context: The Organization had one purchase of equipment that fell under the procurement guidelines, this purchase did not comply with procurement requirements. Recommendation: The Organization should implement a procurement policy and procedure that includes the selection and documentation of procurement rationale and controls and oversight. This policy should be followed for all procurement transactions. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with this finding. The Organization agrees with the recommendations of the auditors and has already prepared a draft procurement policy.

Corrective Action Plan

Audit Finding Reference: 2022-001 Material audit adjustments Planned Corrective Action: We will make sure all grants are submitted to development, accounting and executive director at the time of signing as to distinguish if the grant is conditional or not for reporting purposes. In order to better track in-kind donations we have created an intake form managed in the Executive Director?s office and are requiring values to be provided by donors at the time of the in-kind gift. Name of Contact Person: Amanda Blaurock, Executive Director, amanda@villageexchangecenter.org Anticipated completion date: 8/31/2023 Audit Finding Reference: 2022-002 Grant compliance Planned Corrective Action: There have been significant issues with verifying addresses for county purposes due to errors on the websites utilized to verify counties. In addition, we are serving an often transient and migrant population that have attested to being houseless exemplifying the address issues. Upon learning of reporting issues, we immediately self-reported to the grantor and obtained verbal and written approval to proceed. We also immediately put procedures in place and made staff level adjustments. We have already implemented new procedures to confirm and document that the Executive Director and the program, grants, and finance teams review all reports before submission to grantors. Name of Contact Person: Amanda Blaurock, Executive Director, amanda@villageexchangecenter.org Anticipated completion date: Completed Audit Finding Reference: 2022-003 Procurement Planned Corrective Action: There was only one transaction that fell under these standards in 2022 and it was approved by the grantor. We did price comparisons, but did not have the specific written documents as prescribed by the standards. We will develop a procedure manual to ensure that proper action is taken at the time the invoice is submitted for approval. We anticipate having this procedure manual ready by the end of the first quarter of the fiscal year. Name of Contact Person: Amanda Blaurock, Executive Director, amanda@villageexchangecenter.org Anticipated completion date: March, 2024

Categories

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

Other Findings in this Audit

  • 609471 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $168,884
97.008 Non-Profit Security Program $56,009
10.225 Community Food Projects $38,284
21.027 Coronavirus State and Local Fiscal Recovery Funds $30,850
14.218 Community Development Block Grants/entitlement Grants $22,811