Finding Text
2021-004: Procurement and Suspension and Debarment:
Federal Program: Assistance Listing Nos.: 14.267 Continuum of Care Program
Condition: The organization was unable to demonstrate controls over the procurement for five items selected for testing.
Criteria: The requirements that apply to procurement under grants and cooperative agreements are contained in 2 CFR sections 200.317 through 200.326, program legislation, federal awarding agency regulations, and the terms and conditions of the award. The requirements that apply to procurement under cost-reimbursement contracts under the FAR are contained in 48 CFR parts 03, 15, 44 and the clauses at 48 CFR sections 52.244-2, 52.244-5, 52.203-13, 52.203-16, and 52.215-12; agency FAR Supplements; and the terms and conditions of the contract.
Questioned Costs: There were six expenses that no support could be provided to support the expense took place during grant period as such there is a question cost of $2,447.
Effect: The Organization could have expenses that were paid that did not meet their own procurement policy.
Cause: The Organization did not have good controls on ensuring the procurement requirement was meet due to staff turn over and being unable to locate documentation.
Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management enhance a set of controls to ensure that they are able to demonstrate that all expenses meet their procurement policy.
Perspective: This is a systemic issue in that controls over the requirement are not being adhered to ensure no issues arise.
Repeat: This is not a repeat finding.
Responsible Official’s View: The Organization agrees with the finding. See attached corrective action plan.