Finding 396646 (2022-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-05-14

AI Summary

  • Core Issue: Astraea failed to document required screenings of vendors and employees against U.S. Government's exclusion lists, risking payments to ineligible parties.
  • Impacted Requirements: Compliance with CFR 200.213 and U.S. Government regulations on terrorism screening is mandatory for federal assistance programs.
  • Recommended Follow-Up: Astraea should create a clear policy for screenings and documentation, and train staff to ensure adherence to these requirements.

Finding Text

Finding 2022-006: Suspension and Debarment and U.S. Government Regulations on Terrorism Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: CFR 200.213 states that non-Federal entities are subject to the non-procurement 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. Additionally, as outlined in each Department of State award, recipients of U.S. Government funds must adhere to the United States Government’s requirements on screening all potential vendors, suppliers, sub-contractors/grantees and employees against the United States Department of State’s Terrorism watch list. The screening of all potential vendors, suppliers, subcontractors/ grantees and employees must be documented in writing. Condition: Astraea did not provide documentation to support its screenings for its potential and current vendors, suppliers, contractors, employees, etc. that were paid with Federal funds. Cause: Astraea did not have a procedure in place to ensure all required screenings are performed and documentation to support the screening is maintained. Context: During our audit, we inquired of evidence of such a process, and Astraea was unable to provide support with respect to this area. It should be noted, that Astraea did perform and document the required screenings in January 2023 (in response to the finding issued during the fiscal year 2021 audit finding). Effect: Astraea could make payments to an entity or individual that has been debarred or suspended by the US Government; such costs would be disallowed, and Astraea could face consequences for lack of compliance. Questioned Costs: None noted. Identification as a Repeat Finding: Yes - Finding 2021-007. Recommendation: We recommend Astraea develop a policy of how screenings will be performed and how documentation will be maintained in order to demonstrate compliance with government regulations. 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: Due diligence practices have been improved within Astraea since FY2022 as team members with relevant experience and technical skills have been brought on to reform and implement our screening and documentation processes. First, the Awards Management team has been strengthened and expanded. In 2023, the Awards Management team instituted policies for screening of all awards (grants, sub-grants, contracts), and all relevant staff members were trained on the new award policies. It is important to note that Astraea consistently sought approval from its AOR for grants and subgrants prior to putting internal infrastructure in place to ensure that these screenings are performed. As noted above, Astraea updated its procurement policies in FY2022 to require documented screening for all vendors, suppliers, and contractors. All staff members are regularly trained on best practices to undertake and document these screenings- most recently in FY2024. Potential Astraea employees are subject to rigorous background checks as part of the hiring processes. The Finance, Operations, and Program teams have developed internal processes to ensure that all procurement flows through the organization are documented and in compliance with CFR200. Team members responsible for contracting in all areas of Astraea’s work stream will undergo regular training to ensure that screenings are done promptly and effectively, with clear documentation of such screenings. Anticipated Completion Date: June 30, 2024 Responsible Officials: Associate Director, Grants Management and Compliance; Director of Program Operations, Executive Director

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 396643 2022-003
    Material Weakness Repeat
  • 396644 2022-004
    Material Weakness Repeat
  • 396645 2022-005
    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