Finding 513966 (2024-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-12-12

AI Summary

  • Core Issue: The Organization failed to check for vendor suspension or debarment before using a vendor for a federal award.
  • Impacted Requirements: This noncompliance violates federal regulations under 2 CFR Part 200 regarding procurement procedures for federal awards.
  • Recommended Follow-Up: Review the latest Compliance Supplement annually to ensure adherence to all compliance requirements and improve internal controls.

Finding Text

Other Matter/Significant Deficiency Assistance Listing Number title and number: Promotion of the Humanities Challenge Grants, Assistance Listing Number 45.130 Federal award grant number and year: CHA-284001-22; 2024 Federal agency: National Endowment for the Arts Criteria: Auditee requirements contained in Title 2 U.S. Code of Federal Regulations (2 CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and audit Requirements for Federal Awards, requires the auditee to comply with federal statutes, regulations, terms and conditions of federal awards that may have a direct and material effect on each of its major programs. The procurement compliance requirement requires the Organization to perform a search for vendor suspension or debarment prior to any use in conjunction with Federal awards. Condition: Instances of noncompliance have been identified as the Organization did not perform a search for vendor suspension or debarment prior to using such vendor on the major program’s Federal award. Cause: The cause is due to a lack of sufficient internal control procedures in place to ensure compliance with material compliance requirements for its federal award. Effect: The finding resulted in a significant deficiency issued on compliance for major programs. The vendor was subsequently searched and found not to be suspended or debarred. Questioned costs: None. Context: The Organization utilized one vendor in connection with all costs for the major program. Due to the prior use and history with the vendor, the Organization did not perform a search for suspension or debarment on the vendor despite using the vendor for a federal award. Repeat Finding: No. Recommendation: We recommend that the Organization review the most recent Compliance Supplement, which outlines compliance requirements for several of its federal awards. We encourage the Organization to monitor for any updates to the Compliance Supplement annually. Views of responsible officials: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

To address the deficiency in procurement processes, particularly the lack of suspension and debarment checks, management will update the procurement policies to require a suspension/debarment verification before engaging any vendor for federal award funds. This verification process, conducted through the System for Award Management (SAM), has been embedded as a mandatory step in the vendor onboarding workflow. Training sessions will be held to educate staff on compliance requirements under the Uniform Guidance, emphasizing the importance of these checks in safeguarding federal funds. Additionally, a compliance tracker will be implemented to document and monitor the completion of suspension and debarment verifications for all federal fund vendors. To ensure ongoing adherence, a quarterly compliance review will be conducted by the procurement and finance teams. Oversight of these corrective actions has been assigned to Dorian Davis, Corporate Controller and Sylvia Gicheru, Assistant Controller with all measures in place by March 31, 2025.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1090408 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
42.U01 Gershwin Prize - Elton John and Barnie Taupin $925,003
45.130 Promotion of the Humanities Challenge Grants $750,000
93.859 Biomedical Research and Research Training $263,655
47.076 Stem Education (formerly Education and Human Resources) $67,268
42.U01 Teaching with Primary Sources $63,530
84.326 Special Education Technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $54,509
42.U01 Citizen Witness $17,435