Finding 401831 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-06-24

AI Summary

  • Core Issue: The Association failed to keep documentation proving they verified vendors were not suspended or debarred before contracting.
  • Impacted Requirements: This violates 2 CFR Part 1326, which mandates documentation for vendor eligibility in federal procurement.
  • Recommended Follow-up: Ensure proper documentation practices are established and maintained to comply with grant requirements.

Finding Text

Finding 2023-001: Significant Deficiency – Lack of Documentation of Verification of Vendors Federal grantor: Department of Justice Condition: The Association contracts with a vendor and, although they did verify the vendor was not on the list of vendors suspended or debarred from federal contracting before contracting with the vendor, they did not document this verification. Criteria: Entities must comply with 2 CFR Part 1326 that prohibits entities that have been debarred, suspended or voluntarily excluded from participating in Federal procurement. Cause: The grant agreement contains a requirement to verify or receive vendor certification that they are not debarred suspended, ineligible or voluntarily excluded from Federal procurements. Although this procedure was followed based on our discussion with Association staff, documentation was not retained proving that the verification was performed prior to entering into the contract. Effect: We are not able to determine if the Association verified the vendor prior to contracting. Recommendation: We recommend the Association ensure that documentation of compliance with grant requirements is retained for the Association’s records. Management’s Response: Management response to the finding is discussed in the Correction Action Plan.

Corrective Action Plan

Finding Reference Number: 2023-001 – Significant Deficiency – Lack of Documentation of Verification of Vendors Description of Finding: APA verified vendor was neither suspended nor debarred and staff confirmed as such in writing. However, they did not print and/or maintain a copy of the screenshot for files. This was inconsistent with APA written procedures. Statement of Concurrence (or Nonconcurrence): Management concurs that there was one instance wherein it did not print and maintain the verification screenshot for its files. Corrective Action: Management will review and update its procurement procedures to include a contract review checklist to be signed and dated by the preparer and approved by the contract signer (General Counsel, COO or CEO). Said checklist will include a specific reference to the date suspension and debarment were checked and will serve as primary documentary support which will be included in the vendor contract files. Contact Information: For further details or questions regarding this corrective action plan, please contact: Name: Steven Naugle

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Eligibility Significant Deficiency

Other Findings in this Audit

  • 978273 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
16.746 Capital Case Litigation Initiative $169,710
16.582 Crime Victim Assistance/discretionary Grants $158,073
16.738 Edward Byrne Memorial Justice Assistance Grant Program $147,302
16.320 Services for Trafficking Victims $18,475
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $3,719
16.812 Second Chance Act Reentry Initiative $2,510