Finding 561892 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-05-29
Audit: 357546
Organization: US Water Alliance (WA)

AI Summary

  • Core Issue: The Alliance lacks complete documentation for suspension and debarment checks, violating procurement requirements.
  • Impacted Requirements: Non-compliance with 2 CFR Section 200.318 and related procurement standards.
  • Recommended Follow-Up: Review and enhance procurement processes to ensure all necessary documentation is retained.

Finding Text

Criteria: 2 CFR Section 200.318 requires that 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 standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition and context: During testing of the Alliance’s controls on compliance over procurement and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check. Effect: The Alliance was not fully in compliance with the procurement and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over procurement and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.

Corrective Action Plan

Action taken: Management has updated the process to verify that contractors are not suspended or debarred from receiving federal funds. While management was previously reviewing and confirming contractor eligibility, this confirmation was not consistently documented in the contractor records. Effective immediately, management has implemented a new step requiring the inclusion of a physical screenshot from SAM.gov in the contractor records. This adjustment ensures proper documentation and alignment with compliance requirements. Person responsible: ShaQuina Davis, Chief Operating Officer Date completed: February 10, 2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 561893 2024-002
    Significant Deficiency
  • 561894 2024-003
    Significant Deficiency
  • 561895 2024-004
    Significant Deficiency
  • 1138334 2024-001
    Significant Deficiency
  • 1138335 2024-002
    Significant Deficiency
  • 1138336 2024-003
    Significant Deficiency
  • 1138337 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
66.203 Environmental Finance Center Grants $11,655