Finding 394234 (2022-002)

Finding 2022-002: Procurement and Suspension and Debarment  Assistance Listing Number: 19.510  Federal Program: U.S. Refugee Admissions Program  Federal Agency: U.S. Department of State  Pass-Through Entity: Church World Service  Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per guidance 2 CFR section 200.320, non-Federal entities must have and use documented procurement procedures, consistent with the standards of 2 CFR sections 200.320, 200.317, 200.318, and 200.319. Condition: We noted Team Rubicon’s procurement policy was missing key detail, including procurement procedures related to conflicts of interest, the search for suspended and debarred parties, and approved methods of procurement, including the specific situations where noncompetitive procurement is appropriate. Cause: The error was primarily due to a misunderstanding of certain federal compliance requirements. Effect or Potential Effect: A failure to identify federal compliance requirements could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None noted Context: During the year ended December 31, 2022, Team Rubicon was a recipient of a federal award, making Team Rubicon a subrecipient of the award and subject to certain federal compliance requirements including Procurement and Suspension and Debarment. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure compliance with federal statutes, regulations and the terms and conditions of the federal awards. Views of Responsible Official: Management agrees and acknowledges the finding.