Finding Text
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Pass-Through Agencies: Illinois Department of Human Services; New Life Centers of Chicagoland; Illinois Criminal Justice Information Authority
Pass-Through Number: FSCBX06450; 25JAC9145-07A; 823037; 823038
Award Periods: July 1, 2022 through June 30, 2023; September 1, 2022 through August 31, 2025; and September 1, 2022 through June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement:
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g. grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220.
Condition:
Through audit procedures performed, we noted that the Organization does not have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded.
Questioned Costs:
None
Context:
During our testing, we noted a formal policy was not in place over suspension and debarment. We also noted that the Organization did not determine or verify whether one vendor in which a contract was entered into was not suspended or debarred prior to entering into the contract.
Cause:
Policies and procedures had not been put into place to verify whether the Organization is entering into covered transactions with entities that are not suspended or debarred.
Effect:
The possible receipt of federal funds or assistance by an ineligible contractor.
Repeat Finding:
This is not a repeat finding.
Recommendation:
We recommend that current policies and procedures over covered transactions be updated to include one of the following procedures related to suspension and debarment:
• Searching for the person or entity within the Excluded Parties List System; Collecting certification from the person or entity; or
• Adding a clause or condition to the covered transaction with that person or entity
Views of Responsible Officials and Planned Corrective Actions:
There is no disagreement with this finding. Enlace Chicago is committed to ensuring the policies and procedures are being followed in relation to suspension and debarment. The current policy is to search a person or entity within the Excluded Parties List System on an ongoing basis. In addition to the search, moving forward, documentation will include the date of the search and saved within each contractual package. Contract language will also be added to include a clause to cover this internal control requirement.
Name of the contact person responsible for corrective action: Laura Velazques, Director of Finance
Planned completion date for corrective action plan: June 30, 2024