Finding Text
Finding 2023-002: Lack of sufficient documentation to evidence controls over Suspension and Debarment
Identification of the federal programs:
Program Titles: Emergency Solutions Grant Program, Second Chance Act Reentry Initiative
Assistance Listing Numbers: 14.231, 16.812
Award Identification: CT8006 SG 2023-0063, CT8006 SG 2024-0026, CT 8006 SG 2023-0042, N L 20 70C-4, S-L-20-70C-1
Federal Agencies: United States Department of Housing and Urban Development, United States Department of Justice
Pass-through entities: City of Cleveland Department of Community Development, Ohio Development Services Agency
Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition: Lutheran Metropolitan Ministry was not able to provide documentation to evidence controls surrounding Suspension and Debarment compliance requirement for both the Emergency Solutions Grant Program and the Second Chance Act Reentry Initiative.
Cause: Lutheran Metropolitan Ministry’s processes and controls established for Suspension and Debarment compliance requirement related to the major programs did not allow for the retention of documentation to evidence such review and approval was completed.
Effect: There is an increased risk of procuring with vendors that are suspended and debarred.
Questioned costs: None
Context: Lutheran Metropolitan Ministry was not able to evidence controls surrounding the Suspension and Debarment compliance requirement for six out of six vendors tested under the Emergency Solutions Grant Program and for four out of four vendors tested under the Second Chance Act Reentry Initiative.
Recommendation: Lutheran Metropolitan Ministry should evaluate policies and procedures surrounding document retention and ensure that all vendor files include evidence of search and verification that vendors are not suspended and debarred.
Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.