Finding Text
2023-015 Procurement and Suspension and Debarment
Assistance Listing No.: 14.267 Continuum of Care Program
Condition: The Organization was unable to demonstrate consistent controls over the procurement
requirement.
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 is no questioned cost.
Cause: The Organization did not have sufficient controls to ensure that the procurement requirement
was met due to staff turnover.
Effect: The Organization could have expenditures that were paid that did not meet its own
procurement policy.
Perspective: Thirty-one of the forty items selected for testing did not have documentation of the control
over compliance with the procurement and suspension and debartment requirement.
Repeat Finding: This is a repeat finding. See finding 2022-018.
Recommendation: In order to prevent future occurences of this deficiency, we recommend that management
expand controls to ensure that they are able to demonstrate that all expenses meet their
procurement policy.
Auditee Response: The Organization agrees with the finding. See attached corrective action plan.