Finding 529335 (2024-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-21

AI Summary

  • Core Issue: The Agency failed to keep records verifying that vendors were not suspended or debarred before contracting.
  • Impacted Requirements: This violates 2 CFR sections 200.212, 200.318(h), and 180.300, which mandate verification of vendor eligibility.
  • Recommended Follow-Up: Update procurement policies to include vendor verification procedures and maintain documentation to ensure compliance.

Finding Text

2024-002 – Suspension and Debarment Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Continuum of Care Program Assistance Listing Number: 14.267 Federal Award Identification Number: IL1780LST172201 - 2023 IL1651L5Tl42204 - 2023 IL1780L5T172100 - 2022 IL0315LST142215 - 2023 IL1651L5T142103 - 2022 Award Periods: August 1, 2022 – July 31, 2023; August 1, 2023 – July 31, 2024; July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6 outlines that the non-Federal entity must verify that the agency in which it is entering into a contract is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The Agency did not retain the documentation of verification of vendors not suspended or debarred prior to entering into a contract with the vendor. Questioned Costs: None Context: The Agency procured grant writing services and made rental assistance payments to the vendors without maintaining the documentation of verification for the vendors not being suspended or debarred. Cause: Unknown Effect: Formalized procedures should be in place to ensure the Agency does not engage with vendors that are debarred, suspended, or otherwise excluded. Repeat Finding: This finding is not a repeat finding. Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Views of Responsible Officials: There is no disagreement with this audit finding.

Corrective Action Plan

2024-002: Suspension and Debarment Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for debarred, suspended, or excluded and documentation maintained to support the determination. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Dhiren Shah, CFO, at 630-248-1181.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 529334 2024-001
    Significant Deficiency
  • 1105776 2024-001
    Significant Deficiency
  • 1105777 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.267 Continuum of Care Program $797,523
93.959 Block Grants for Prevention and Treatment of Substance Abuse $366,576
93.276 Drug-Free Communities Support Program Grants $124,730
93.667 Social Services Block Grant $117,596
93.550 Transitional Living for Homeless Youth $62,320
93.569 Community Services Block Grant $55,378
14.218 Community Development Block Grants/entitlement Grants $13,610