Finding Text
Finding #2023-003 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of State: Passed through U. S. Committee for Refugees and Immigrants, 19.510, U. S. Refugee Admissions Program, Contract periods and grant #’s: 10/01/23 – 09/30/24 SPRMCO23CA0367, 09/01/22 – 09/30/23 SPRMCO23CA0012, 04/15/22 – 09/30/22 SFOP0008350, U. S. Department of Health and Human Services: Passed through U. S. Committee for Refugees and Immigrants, 93.567, Refugee and Entrant Assistance Voluntary Agency Programs, Contract periods and grant #’s: 10/01/23 – 09/30/24 2402VARVMG-00, 10/01/21 – 09/30/23 2202VARVMG, Passed through U. S. Committee for Refugees and Immigrants, 93.576, Refugee and Entrant Assistance Discretionary Grants, Contract periods and grant #’s: 09/30/23 – 09/29/24 90RP0119, 09/30/22 – 09/29/23 90RP0119, 09/30/21 – 09/29/23 90RP0119, 09/30/22 – 09/29/23 90RP0119-01-01, 09/30/21 – 09/29/23 90RP0119-01-03, 09/30/23 – 09/29/24 90ORP0119, 09/30/23 – 09/29/24 90RP0119, 09/30/23 – 09/29/24 90RP0119-02-04, Passed through U. S. Committee for Refugees and Immigrants, 93.676, Unaccompanied Alien Children Program, Contract period and grant #: 01/01/21 – 12/31/23 90ZU0357. Criteria: Procurement – Nonprofit organizations are required to conduct procurement transactions in a manner providing full and open competition consistent with standards prescribed in Uniform Guidance, Subtitle III Procurement Standards and conform to federal and state laws and regulations and other contractual requirements. Uniform Guidance requires public notice for proposal requests for purchases over the Simplified Acquisition Threshold, as defined by the nonprofit organization’s policy, which for the YMCA is $150,000. Condition and context: During our testing of a sample of 8 expenditures requiring procurement, we identified that a competitive procurement for contracted client transportation expenditures greater than $150,000 was not performed. Additionally, documentation of policy change for people to authorize procurement decisions was not updated in the procurement policy, nor was it approved by a board action. This is a repeat of finding #2022-003. Cause: Failure to follow the YMCA’s procurement policy by those responsible for procurement and failure to timely update and obtain approval of changes to its procurement policy. Effect: Failure to follow formal procurement methods may result in the YMCA purchasing goods or services for more than would be necessary if required competitive procurement procedures had been followed. Failure to update approval authority for procurements could result in inappropriate procurement authorizations. Recommendation: Provide additional education to employee’s responsible for procurement on the YMCA’s procurement policy and update policies in a timely manner. Views of responsible officials: Management agrees with the finding. See Corrective Action Plan.