Finding Text
2024-001: Suspension and Debarment
Program: Child and Adult Care Food Program (ALN 10.558)
Federal agency: U.S. Department of Agriculture
Pass-through entity name and identifying number:
Maryland State Department of Education (347105)
District of Columbia OSSE (N/A)
Virginia Department of Health (4108)
Federal Award Year: Year ended June 30, 2024
Program: Commodity Supplemental Food Program (ALN 10.565)(Food Distribution Cluster)
Federal agency: U.S. Department of Agriculture
Pass-through entity name and identifying number:
District of Columbia Department of Health (CHA2022-000027)
Montgomery County Department of Health and Human Services (1087608)
Maryland Department of Aging (N/A)
Federal Award Year: Year ended June 30, 2024
Program: Emergency Food Assistance Program (Administrative Costs) (ALN 10.568)(Food Distribution Cluster)
Federal agency: U.S. Department of Agriculture
Pass-through entity name and identifying number:
Virginia Department of Agriculture and Consumer Services (VDACS) (67-150)
District of Columbia OSSE Wellness and Nutrition Services Division (CW102461)
District of Columbia Department of Health (N/A)
Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012-FY23 and FIA/FNS 23-012-FY 24)
Federal Award Year: Year ended June 30, 2024
Program: Emergency Food Assistance Program (Commodities) (ALN 10.569)(Food Distribution Cluster)
Pass-through entity name and identifying number:
District of Columbia OSSE Wellness and Nutrition Services Division (CW102461)
District of Columbia Department of Health (N/A)
Virginia Department of Agriculture and Consumer Services (VDACS) (67-150)
Maryland Department of Human Resources Family Investment Administration (FIA/FNS 23-012)
Federal agency: U.S. Department of Agriculture
Federal Award Year: Year ended June 30, 2024
Program: COVID-19: Coronavirus State and Local Recovery Funds (ALN 21.027)
Federal agency: U.S. Department of the Treasury
Pass-through entity name and identifying number:
Federation of Virginia Food Banks (N/A)
Federation of Virginia Food Banks – Farms to Families Box Program (N/A)
Fairfax County (#SR-003432J)
D.C. Department of Health (CHA2022-000020-1)
Office of the Deputy Mayor for Planning and Economic Development (PO690289-FY23-DMPED)
City of Falls Church (N/A)
VA Department of Agricultural Services (2022-4A1-001)
Prince William County (N/A)
Federal Award Year: Year ended June 30, 2024
Type of finding: Material Weakness in Internal Control over Compliance
Criteria: As stated in 2 CFR 200.214 Suspension and debarment, recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. As noted in 2 CFR 180.155, this verification may be accomplished by checking the System for Award Management (SAM.gov) exclusions to determine whether a person is excluded. 2 CFR 180.220(b)(1) indicates that contracts for goods or services where the amount is expected to equal or exceed $25,000 are covered transactions for the suspension and debarment requirement.
Condition: We noted that, although CAFB has a written process for checking suspension and debarment, CAFB did not have documentation of a suspension and debarment check on procurements greater than $25,000 that we selected for testing in three major programs.
Cause: The review process related to suspension and debarment did not occur as intended.
Effect: Although not found in our testing, procurements could have been made to suspended or debarred parties.
Context: Applies to controls over ensuring vendors are properly vetted and are not suspended or debarred.
Questioned costs: None
Repeat finding: No
Recommendation: We recommend that the organization ensure the written procedures around suspension and debarment are followed.
Views of responsible officials: CAFB has reviewed and agrees with the finding and the recommendation.