FAC Explorer

Finding 396645 (2022-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-05-14
Audit: 306244
Organization: The Astraea Foundation, Inc. (NY)
Auditor: Gelman Rosenberg & Freedman

AI Summary

  • Core Issue: Astraea's procurement policy lacks clear procedures for compliance with federal regulations, leading to potential noncompliance.
  • Impacted Requirements: CFR 200.318-327 mandates documented procurement procedures, which Astraea has not fully implemented.
  • Recommended Follow-Up: Update the procurement policy to align with CFR 200 and train staff on the new procedures to ensure compliance.

Finding Text

Finding 2022-005: Procurement Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: Astraea's procurement policy references CFR 200.318-327 however the policy does not note how it will comply with the requirements and what the process is to ensure compliance is achieved. During our audit we noted multiple instances where vendors were engaged without any documentation of procurement process or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Astraea does not have a procedure in place to ensure all vendors or suppliers paid with Federal funding are engaged in compliance with the Federal regulations. Context: Without updating the policy to comply with CFR 200, Astraea is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Astraea may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: Yes - 2021-006. Recommendation: We recommend Astraea update the procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: Astraea created a best practice procurement policy in December 2021 that was implemented in February 2022 (i.e. Q3 of FY2022). Prior to December 2021, procurement practices were not standardized across the organization. Since implementation of the current procurement policy, all staff members have been trained on the procurement policy, and the Finance and Operation teams have developed internal processes to ensure that all procurement flows through the organization are documented and in compliance with 2 CFR 200. With the policy in place, we recognize that implementation across teams is critical and are actively training people managers to improve oversight and improve implementation. Anticipated Completion Date: January 31, 2024 Responsible Official: Associate Director, Grants Management and Compliance; Director of Program Operations

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 396643 2022-003
    Material Weakness Repeat
  • 396644 2022-004
    Material Weakness Repeat
  • 396646 2022-006
    Material Weakness Repeat
  • 396647 2022-007
    Material Weakness
  • 973085 2022-003
    Material Weakness Repeat
  • 973086 2022-004
    Material Weakness Repeat
  • 973087 2022-005
    Material Weakness Repeat
  • 973088 2022-006
    Material Weakness Repeat
  • 973089 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $2.76M
19.345 International Programs to Support Democracy, Human Rights and Labor $171,734