Finding 567629 (2024-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-06-26
Audit: 360178
Organization: Hias, Inc. (MD)

AI Summary

  • Core Issue: HIAS failed to document required checks for vendors to ensure they are not debarred or suspended from federal programs.
  • Impacted Requirements: Non-compliance with §200.213, which mandates verification of vendor eligibility through SAM Exclusions.
  • Recommended Follow-Up: Improve procedures to conduct and document SAM screenings for all vendors associated with federal awards.

Finding Text

Finding 2024-004 Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program Criteria or Specific Requirement: §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that 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; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted contractual relationships under the Federal awards for which documentation of SAM Exclusion checks were unavailable for our inspection. Cause: Administrative oversight. Effect or Potential Effect: HIAS could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: $102,541 Context: Our testwork consisted of a sample of 25 vendors charged to the Federal awards under major program ALN #19.510 U.S. Refugee Admissions Program. We noted lack of timely screening documentation for nine of the 25 vendors tested. The control deficiency is considered systemic in nature. Identification as a Repeat Finding: N/A Recommendation: We recommend that HIAS enhance its procedures to ensure that SAM screenings are run on all contractual relationships that are charged to the Federal awards, and that documentation of such screenings are maintained in the vendor files.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 567627 2024-004
    Significant Deficiency
  • 567628 2024-005
    Significant Deficiency
  • 567630 2024-005
    Significant Deficiency
  • 567631 2024-004
    Significant Deficiency
  • 567632 2024-005
    Significant Deficiency
  • 567633 2024-004
    Significant Deficiency
  • 567634 2024-005
    Significant Deficiency
  • 567635 2024-004
    Significant Deficiency
  • 567636 2024-005
    Significant Deficiency
  • 567637 2024-004
    Significant Deficiency
  • 567638 2024-005
    Significant Deficiency
  • 1144069 2024-004
    Significant Deficiency
  • 1144070 2024-005
    Significant Deficiency
  • 1144071 2024-004
    Significant Deficiency
  • 1144072 2024-005
    Significant Deficiency
  • 1144073 2024-004
    Significant Deficiency
  • 1144074 2024-005
    Significant Deficiency
  • 1144075 2024-004
    Significant Deficiency
  • 1144076 2024-005
    Significant Deficiency
  • 1144077 2024-004
    Significant Deficiency
  • 1144078 2024-005
    Significant Deficiency
  • 1144079 2024-004
    Significant Deficiency
  • 1144080 2024-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.567 Refugee and Entrant Assistance Voluntary Agency Programs $7.02M
98.001 Usaid Foreign Assistance for Programs Overseas $6.53M
19.018 Resettlement Support Centers (rscs) for U.s. Refugee Resettlement $4.09M
19.510 U.s. Refugee Admissions Program $1.31M
19.522 Overseas Refugee Assistance Programs for Strategic Global Priorities $650,002
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $604,267
19.345 International Programs to Support Democracy, Human Rights and Labor $364,948
93.242 Mental Health Research Grants $73,055
19.517 Overseas Refugee Assistance Programs for Africa $60,874
19.040 Public Diplomacy Programs $36,706
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $3,536
93.576 Refugee and Entrant Assistance Discretionary Grants $1,684