Finding 555150 (2023-007)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2025-04-15
Audit: 353757
Organization: Samu Foundation (DC)

AI Summary

  • Core Issue: SAMU failed to properly screen vendors and contractors against debarment lists, risking federal fund misuse.
  • Impacted Requirements: Compliance with 2 CFR §200.213 and related regulations was not met due to lack of documentation and timely screenings.
  • Recommended Follow-Up: Develop a formal policy for vendor screenings, ensure checks are done before contracts, and document screening dates. Notify and enforce this policy among all employees.

Finding Text

Finding 2023-007: Suspension and Debarment Information on the Federal Program: 97.024 - Emergency Food and Shelter National Board Program Type of Finding: Material Weakness in Internal Control over Compliance and Material NoncomplianceCriteria: Under 2 CFR §200.213, non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: During our testing over Suspension and Debarment, we determined that SAMU either did not perform screenings, or did not document the screening date on potential or current vendors, suppliers, contractors or employees that were paid with Federal funds. Cause: SAMU does not have a formal internal policy with respect to screening vendors, suppliers, contractors and employees in order to adhere to compliance over suspension and debarment. Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment occurs) potential and current vendors, suppliers, contractors and employees increases the potential that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the United States Government. Questioned Costs: $24,000 Context: Out of 4 samples selected for testing, we noted the following: 2 samples did not have evidence of the date of the SAM check being performed; 1 sample had a SAM check date performed after execution of the contract with the vendor; 1 sample did not have a SAM check performed at all. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: 2022-007 Recommendation: We recommend that management develop and implement a formal policy on suspension and debarment. All screenings should be conducted prior to entering into an agreement with a vendor. Additionally, evidence of documentation should include the date of when the SAM check was performed. We recommend that SAMU notify all employees of this policy and ensure that it is enforced during the upcoming year.

Corrective Action Plan

Views of Responsible Officials: SAMU will develop a comprehensive corrective action plan that addresses: 1. Creation and implementation of a formal suspension and debarment screening policy 2. Establishment of a documented screening process with clear timelines 3. Training program for staff on federal requirements and internal procedures 4. Regular monitoring and internal audit procedures By implementing these measures, SAMU can strengthen its compliance with federal regulations, mitigate the risk of providing funds to suspended or debarred parties, and protect its federal funding sources.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 555146 2023-003
    Significant Deficiency
  • 555147 2023-004
    Material Weakness
  • 555148 2023-005
    Significant Deficiency Repeat
  • 555149 2023-006
    Material Weakness Repeat
  • 555151 2023-008
    Significant Deficiency Repeat
  • 1131588 2023-003
    Significant Deficiency
  • 1131589 2023-004
    Material Weakness
  • 1131590 2023-005
    Significant Deficiency Repeat
  • 1131591 2023-006
    Material Weakness Repeat
  • 1131592 2023-007
    Material Weakness Repeat
  • 1131593 2023-008
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
97.024 Emergency Food and Shelter National Board Program $4.33M