FAC Explorer

Finding 485099 (2023-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-08-26
Audit: 317890
Organization: City and County of Denver (CO)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The City department of HOST lacked effective controls for ensuring compliance with suspension and debarment requirements for subrecipients.
  • Impacted Requirements: Compliance with 2 CFR Section 200.303, which mandates internal controls for Federal awards.
  • Recommended Follow-Up: HOST should implement a checklist to ensure SAM.gov searches are conducted and documented before contracting with subrecipients.

Finding Text

PROCUREMENT AND SUSPENSION AND DEBARMENT (FOR SUBRECIPIENTS) Significant Deficiency in Internal Control Over Compliance ALN 14.231 – Emergency Solutions Grant Program Department of Housing and Urban Development Award Number: E-20-MW-08-0005, E-20-MC-08-0005, E-21-MC-08-0005, E-22-MC-08-0005 Award Year: 2020, 2021, 2022 Criteria or Specific Requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The City department of HOST did not have effectively operating controls in place to ensure policies and procedures were followed with respect to suspension and debarment. HOST did have a compensating control in place pertaining to review of contracts to ensure suspension and debarment certifications were present. This was a finding carried over from the prior period. There were no new contracts entered into with subrecipients during 2023. Cause: The department’s review control was not operating effectively to ensure suspension and debarment searches were being performed. No documentation was retained to support such review took place. Effect or Potential Effect: The Department could potentially enter into contracts with subrecipients or vendors who were included on the suspension and debarment listing at SAM.gov. Questioned Costs: Not applicable Context: The control finding was remediated in 2023. However, the control was not present at the time the City entered into agreements with its subrecipients prior to 2023. No control testing was performed because no controls were in operation at the time of award. Identification as a Repeat Finding: This is a repeat finding from the prior year. This was reported as finding 2022-008 in the 2022 report. Recommendation: HOST should follow their documented internal control procedures to ensure the SAM.gov search is performed, and documentation is retained to support compliance with internal policies and procedures related to suspension and debarment. A checklist or other tool should be developed to ensure this has been performed prior to contracting. Views of Responsible Officials: The City agrees with the finding. This has been remediated. For additional information, see the City’s separate report for planned corrective actions.

Corrective Action Plan

Status: Complete Corrective Action: This matter has been remediated, however, per the assessment this issue is a carryover into 2023 sub-awards based on the contract timeframes. The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to address the finding prior to December 31, 2022.To remediate prior findings 2022-008 and 2021-011, HOST updated the agency’s Contract & Performance Management Policies under Section VII. Procedure Process Map, Step 1 to include the requirement to verify Suspension and Debarment for all subgrantees utilizing federal funding. This policy was modified and completed in July 2023, and a copy of this was provided to BDO on August 16, 2023, in response to the finding. This issue has been remediated, however, per the assessment, this issue is a carryover into 2023 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST – Jon Luper Implementation Date: July 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 485097 2023-002
    Significant Deficiency Repeat
  • 485098 2023-002
    Significant Deficiency Repeat
  • 485100 2023-003
    Significant Deficiency Repeat
  • 485101 2023-004
    Material Weakness Repeat
  • 485102 2023-004
    Material Weakness Repeat
  • 485103 2023-005
    Significant Deficiency Repeat
  • 485104 2023-006
    Significant Deficiency
  • 485105 2023-006
    Significant Deficiency
  • 485106 2023-007
    Significant Deficiency
  • 485107 2023-008
    Significant Deficiency Repeat
  • 485108 2023-009
    Material Weakness
  • 485109 2023-009
    Material Weakness
  • 1061539 2023-002
    Significant Deficiency Repeat
  • 1061540 2023-002
    Significant Deficiency Repeat
  • 1061541 2023-003
    Significant Deficiency Repeat
  • 1061542 2023-003
    Significant Deficiency Repeat
  • 1061543 2023-004
    Material Weakness Repeat
  • 1061544 2023-004
    Material Weakness Repeat
  • 1061545 2023-005
    Significant Deficiency Repeat
  • 1061546 2023-006
    Significant Deficiency
  • 1061547 2023-006
    Significant Deficiency
  • 1061548 2023-007
    Significant Deficiency
  • 1061549 2023-008
    Significant Deficiency Repeat
  • 1061550 2023-009
    Material Weakness
  • 1061551 2023-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
20.106 Airport Improvement Program $44.36M
93.558 Temporary Assistance for Needy Families $24.33M
93.575 Child Care and Development Block Grant $20.18M
93.778 Medical Assistance Program $15.88M
93.658 Foster Care_title IV-E $13.24M
93.563 Child Support Enforcement $10.64M
14.239 Home Investment Partnerships Program $10.42M
97.141 Shelter and Services Program $8.62M
21.023 Emergency Rental Assistance Program $8.20M
93.914 Hiv Emergency Relief Project Grants $8.11M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $4.97M
93.659 Adoption Assistance $4.23M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $3.73M
93.667 Social Services Block Grant $3.49M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.63M
17.268 H-1b Job Training Grants $2.37M
14.267 Continuum of Care Program $2.12M
14.251 Economic Development Initiative-Special Project, Neighborhood Initiative and Miscellaneous Grants $2.00M
97.106 Securing the Cities Program $1.94M
14.218 Community Development Block Grants/entitlement Grants $1.82M
17.258 Wia Adult Program $1.79M
17.207 Employment Service/wagner-Peyser Funded Activities $1.73M
97.024 Emergency Food and Shelter National Board Program $1.61M
97.044 Assistance to Firefighters Grant $1.48M
14.231 Emergency Solutions Grant Program $1.25M
93.566 Refugee and Entrant Assistance_state Administered Programs $1.23M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.22M
93.569 Community Services Block Grant $1.01M
16.576 Crime Victim Compensation $975,584
93.600 Head Start $948,259
17.259 Wia Youth Activities $910,435
93.994 Maternal and Child Health Services Block Grant to the States $852,989
95.001 High Intensity Drug Trafficking Areas Program $832,198
93.069 Public Health Emergency Preparedness $699,812
17.278 Wia Dislocated Worker Formula Grants $696,231
16.741 Dna Backlog Reduction Program $661,099
20.200 Highway Research and Development Program $634,826
11.307 Economic Adjustment Assistance $572,655
16.738 Edward Byrne Memorial Justice Assistance Grant Program $561,584
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $519,735
93.645 Stephanie Tubbs Jones Child Welfare Services Program $510,280
16.922 Equitable Sharing Program $504,048
20.600 State and Community Highway Safety $458,685
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $392,485
10.558 Child and Adult Care Food Program $377,436
17.277 Workforce Investment Act (wia) National Emergency Grants $360,680
93.090 Guardianship Assistance $332,157
93.268 Immunization Cooperative Agreements $304,183
17.270 Reintegration of Ex-Offenders $251,658
15.435 Gomesa $238,549
93.556 Promoting Safe and Stable Families $210,566
97.067 Homeland Security Grant Program $200,564
17.285 Apprenticeship USA Grants $190,350
10.551 Supplemental Nutrition Assistance Program $183,375
20.616 National Priority Safety Programs $178,539
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $175,589
21.027 Coronavirus State and Local Fiscal Recovery Funds $171,949
93.136 Injury Prevention and Control Research and State and Community Based Programs $166,654
16.817 Byrne Criminal Justice Innovation Program $157,424
16.575 Crime Victim Assistance $148,987
16.710 Public Safety Partnership and Community Policing Grants $148,794
21.017 Social Impact Partnerships to Pay for Results Act (sippra) (b) $147,858
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $146,172
45.149 Promotion of the Humanities_division of Preservation and Access $146,141
16.588 Violence Against Women Formula Grants $144,625
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $136,970
16.034 Coronavirus Emergency Supplemental Funding Program $129,437
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $127,030
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $122,250
17.225 Unemployment Insurance $117,470
16.753 Congressionally Recommended Awards $116,429
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $110,145
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $97,289
16.582 Crime Victim Assistance/discretionary Grants $89,890
16.036 Prosecuting Cold Cases Using Dna $88,917
97.042 Emergency Management Performance Grants $88,047
94.006 Americorps $84,546
11.024 Build to Scale $82,685
93.648 Child Welfare Research Training Or Demonstration $75,683
84.425 Education Stabilization Fund $75,594
93.747 Elder Abuse Prevention Interventions Program $75,046
93.568 Low-Income Home Energy Assistance $69,163
16.609 Project Safe Neighborhoods $66,882
16.320 Services for Trafficking Victims $54,246
45.309 Museum Grants for African American History and Culture $54,154
17.245 Trade Adjustment Assistance $43,897
93.317 Emerging Infections Programs $43,751
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $42,636
93.991 Preventive Health and Health Services Block Grant $38,000
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $35,222
45.313 Laura Bush 21st Century Librarian Program $32,772
20.205 Highway Planning and Construction $18,000
93.670 Child Abuse and Neglect Discretionary Activities $16,374
15.658 Natural Resource Damage Assessment and Restoration $13,267
66.605 Performance Partnership Grants $11,742
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $11,342
10.664 Cooperative Forestry Assistance $10,006
17.801 Jobs for Veterans State Grants $7,644
10.555 National School Lunch Program $5,944
14.241 Housing Opportunities for Persons with Aids $2,510
66.808 Solid Waste Management Assistance Grants $2,491
21.019 Coronavirus Relief Fund $-6