Finding 539639 (2024-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 350179
Organization: Nbcc (CA)

AI Summary

  • Core Issue: NBCC's procurement policy is not being followed, leading to noncompliance with Federal guidelines.
  • Impacted Requirements: Failure to obtain competitive bids and verify vendor eligibility violates CFR 200.318.
  • Recommended Follow-Up: Implement and enforce internal controls to ensure adherence to procurement policies aligned with Federal standards.

Finding Text

Criteria Part 2, CFR 200, 200.318 states “The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.” Condition While performing tests of NBCC’s internal controls over compliance, while the Organization did have a procurement policy, the policy was not being followed. This included not obtaining and documenting competitive bids or quotes, as well as not verifying whether vendors are suspended or debarred entities. Cause NBCC’s internal controls are not properly designed and enforced to be in line with Federal guidelines. Repeat Finding No. Effect Noncompliance may impact future funding from Federal awards. Additionally, lack of compliance may lead to contracting with ineligible vendors. Recommendation We recommend NBCC implement proper internal control procedures including implementing and following a procurement policy in line with the Uniform Guidance.

Corrective Action Plan

x. Management Response and Corrective Action Plan: The first of the two identified vendors – Maxim/Amergis - is an employment agency with a specialty in staffing providers who work in the healthcare and social services field. NBCC was seeking to hire an RN. Significant documentable effort was invested in hiring an RN with the necessary experience to fill our vacant RN Healthcare Navigator position. After months of being unable to find an appropriate candidate, NBCC sought consultation from the Santa Barbara County Department of Public Health who advised us of the name of the employment agency (Maxim/Amergis) that is used by the Department of Public Health and Department of Behavioral Wellness to staff their RN positions. We reached out to Maxim/Amergis, provided them with the job listing, and reviewed resumes and interviewed candidates until we found an appropriate match. This was a prolonged and involved process where we spent a significant amount of time working to hire the best suited RN for working in the field with the homeless and formerly homeless individuals we serve. We did not perceive this to be a traditional procurement effort and therefore did not create a written analysis of our efforts to identify and hire an RN, nor did we conduct a SAM search on the company given that the company routinely staffs our departments of behavioral and public health. The second identified vendor is Paychex. We believe our efforts to secure a new payroll solution company were very much aligned with Uniform Guidance rules. Our external accounting firm and multiple staff spent more than one year interviewing multiple potential payroll solution providers, including but not limited to, Paychex, ADP, ClickUp, Inova, Credible, and Replicon, among others. We only reviewed two written cost proposals because only two of the researched and consulted companies were able to provide a solution that could potentially meet our government timesheet needs. We conducted multiple meetings with our external accounting firm and internal staff discussing and analyzing the solution options, but a summary of these discussions was not created. In addition, Paychex is a provider to a number of nonprofits we consulted, including a local grantee who was using their service, and who we were advised had developed a system similar to what we needed for our time and activity reporting requirements. We therefore presumed Paychex was not a debarred contractor given that other nonprofits we spoke to who have the same funding were utilizing their services. Moving forward, we recognize we must write a written analysis of our processes and that we should not assume a vendor has not been debarred given their existing customers and will be sure to confirm a company’s standing on SAM. As a further example of our commitment to always remaining current with procurement standards, at the direction of the Executive Director, our Operations Director had previously enrolled in a two-day Procurement Boot Camp training which occurred this week. Our Operations Director will revisit our procurement process as a result of this finding and after attending the procurement training and will make revisions to our procurement process as necessary to ensure future compliance with Uniform Guidance. Any updates will be made to the NBCC Internal Controls Manual and any new processes will be adhered to subsequent to those revisions. xi. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Brenda Lang, Operations Director, blang@sbnbcc.org Michael Dzierski, Finance Director, mdzierski@sbnbcc.org xii. Anticipated Completion Date: The anticipated completion date is May 31, 2025.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 539637 2024-002
    Significant Deficiency
  • 539638 2024-003
    Significant Deficiency
  • 539640 2024-005
    Significant Deficiency
  • 539641 2024-002
    Significant Deficiency
  • 539642 2024-004
    Significant Deficiency
  • 539643 2024-002
    Significant Deficiency
  • 539644 2024-004
    Significant Deficiency
  • 539645 2024-002
    Significant Deficiency
  • 539646 2024-004
    Significant Deficiency
  • 1116079 2024-002
    Significant Deficiency
  • 1116080 2024-003
    Significant Deficiency
  • 1116081 2024-004
    Significant Deficiency
  • 1116082 2024-005
    Significant Deficiency
  • 1116083 2024-002
    Significant Deficiency
  • 1116084 2024-004
    Significant Deficiency
  • 1116085 2024-002
    Significant Deficiency
  • 1116086 2024-004
    Significant Deficiency
  • 1116087 2024-002
    Significant Deficiency
  • 1116088 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $317,640
64.033 Va Supportive Services for Veteran Families Program $277,994
14.267 Continuum of Care Program $164,345
14.239 Home Investment Partnerships Program $157,142
14.871 Section 8 Housing Choice Vouchers $73,306
14.231 Emergency Solutions Grant Program $68,280
14.219 Deleted $42,295
14.218 Community Development Block Grants/entitlement Grants $25,788