Finding Text
Federal Program Title(s):
ALN 14.267 – Continuum of Care Program
ALN 16.575 - Crime Victim Assistance
Federal Agencies:
Department of Housing and Urban Development (ALN 14.267)
Department of Justice (ALN 16.575)
Pass-Through Agencies:
New Mexico Crime Victims Reparation Commission (ALN 16.575)
Award Numbers and Periods:
NM0056L6B012001 (7/1/2021-6/30/2022) (14.267)
NM0129D6B011901 (11/1/2020-10/31/2021) (14.267)
NM0129D6B012002 (11/1/2021-10/31/2022) (14.267)
2021-VA-979 (10/1/2020-9/30/2021) (16.575)
2022-VA-180 (10/1/2021-9/30/2022) (16.575)
Type of Finding:
Material Weakness in Internal Control over Compliance
Material Noncompliance (Modified Opinion)
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Award requires compliance with the provisions of
suspension and debarment. VSS should have internal controls designed to ensure compliance with this
provision. 2 CFR 200.318-200.321 outline requirements maintain records sufficient to detail the history
of procurement, requirements for competition, methods and purchasing thresholds, as well as other
requirements for contracting with organizations with using federal funds. VSS’s policies do not meet
these requirements.
Condition: During our testing, we noted that VSS internal controls and accounting policies were not
sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors
used are not suspended or debarred.
Questioned costs: None. VSS did not enter into any contracts with disallowed parties, and there were
no issues with mircopurchases tested. VSS policies and procedures do not contain necessary controls
to ensure compliance with the requirements for suspension and debarment or procurements. As such,
they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition.
Cause: Lack of established controls and procedures over requirements for procurements and federal
principals for suspension and debarment.
Effect: Possible noncompliance with federal requirements for procurements using federal monies.
Possibility to enter into a covered transaction with a noneligible contractor or vendor.
Repeat Finding: 2021-003
Recommendation: We recommend that VSS reviews the current financial policies and procedures in
order to better serve the organization in documenting compliance with federal cost principals and
requirements.
Views of responsible officials: There is no disagreement with the audit finding. VSS accepts this
finding and has contacted an outsourced CPA for review and update of our policies to meet federal cost
principals and requirements. These are currently pending approval by the Board of Directors for
implementation.