Finding 396451 (2023-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-05-10

AI Summary

  • Core Issue: CVT failed to conduct required suspension and debarment screenings before signing contracts or making payments, including for expatriate employees.
  • Impacted Requirements: Non-compliance with 2 CFR §200.213 and related regulations, which mandate screenings to prevent funding to ineligible parties.
  • Recommended Follow-Up: Implement training for staff on screening policies and revise the suspension and debarment policy to include expatriate employee screenings.

Finding Text

Finding 2023-002: Non-Compliance with Suspension and Debarment Information on the Federal Programs: 19.517; 19.519; 98.001 Criteria or Specific Requirement: Under 2 CFR §200.213, on-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over suspension and debarment, we noted that while CVT did run screenings on all selected vendors, suppliers and contractors, the screening was not conducted prior to the signing of the contract or prior to payment. Additionally, we noted that screenings are not run on expatriate employees. Cause: Controls are not adequately designed to ensure that screenings are run prior to contract ,signing or payment. CVT's suspension and debarment policy does not require screenings to be conducted on expatriate employees. Effect or Potential Effect: Failure to screen potential and current vendors, suppliers, contractors and expatriate employees prior to contract signing or payment increases the potential that Federal funds will be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: None noted. Context: We selected a sample of vendors, suppliers, contractors and expatriate employees engaged ,under this program. The sample was a statistically valid sample. Identification as a Repeat Finding: 2022-001 Recommendation: We recommend that management ensure trainings are conducted to ensure staff understand the current policy and specifically communicate that screenings should be conducted prior to contract signing or payment. Additionally, CVT should revise their suspension and debarment policy to include the requirement that screenings be conducted on expatriate employees.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 396444 2023-002
    Significant Deficiency Repeat
  • 396445 2023-002
    Significant Deficiency Repeat
  • 396446 2023-002
    Significant Deficiency Repeat
  • 396447 2023-002
    Significant Deficiency Repeat
  • 396448 2023-002
    Significant Deficiency Repeat
  • 396449 2023-002
    Significant Deficiency Repeat
  • 396450 2023-002
    Significant Deficiency Repeat
  • 396452 2023-002
    Significant Deficiency Repeat
  • 396453 2023-002
    Significant Deficiency Repeat
  • 396454 2023-002
    Significant Deficiency Repeat
  • 396455 2023-002
    Significant Deficiency Repeat
  • 396456 2023-003
    Significant Deficiency Repeat
  • 396457 2023-003
    Significant Deficiency Repeat
  • 396458 2023-003
    Significant Deficiency Repeat
  • 396459 2023-003
    Significant Deficiency Repeat
  • 396460 2023-003
    Significant Deficiency Repeat
  • 396461 2023-003
    Significant Deficiency Repeat
  • 396462 2023-003
    Significant Deficiency Repeat
  • 396463 2023-003
    Significant Deficiency Repeat
  • 972886 2023-002
    Significant Deficiency Repeat
  • 972887 2023-002
    Significant Deficiency Repeat
  • 972888 2023-002
    Significant Deficiency Repeat
  • 972889 2023-002
    Significant Deficiency Repeat
  • 972890 2023-002
    Significant Deficiency Repeat
  • 972891 2023-002
    Significant Deficiency Repeat
  • 972892 2023-002
    Significant Deficiency Repeat
  • 972893 2023-002
    Significant Deficiency Repeat
  • 972894 2023-002
    Significant Deficiency Repeat
  • 972895 2023-002
    Significant Deficiency Repeat
  • 972896 2023-002
    Significant Deficiency Repeat
  • 972897 2023-002
    Significant Deficiency Repeat
  • 972898 2023-003
    Significant Deficiency Repeat
  • 972899 2023-003
    Significant Deficiency Repeat
  • 972900 2023-003
    Significant Deficiency Repeat
  • 972901 2023-003
    Significant Deficiency Repeat
  • 972902 2023-003
    Significant Deficiency Repeat
  • 972903 2023-003
    Significant Deficiency Repeat
  • 972904 2023-003
    Significant Deficiency Repeat
  • 972905 2023-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $2.39M
93.576 Refugee and Entrant Assistance_discretionary Grants $330,793
19.519 Overseas Refugee Assistance Program for Near East and South Asia $181,854
19.990 International Justice and Accountability Programming $96,053
19.345 International Programs to Support Democracy, Human Rights and Labor $72,237
16.575 Crime Victim Assistance $58,062
93.958 Block Grants for Community Mental Health Services $57,692
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $23,921
19.517 Overseas Refugee Assistance Programs for Africa $9,936
93.604 Assistance for Torture Victims $9,461
21.027 Coronavirus State and Local Fiscal Recovery Funds $4,379