Finding 572973 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-06

AI Summary

  • Core Issue: The entity failed to document verification checks to ensure vendors/subrecipients are not suspended or debarred before contracts are signed.
  • Impacted Requirements: This violates Federal Government compliance requirements outlined in 2 CFR section 180.995.
  • Recommended Follow-Up: Implement a control to ensure verification checks are documented prior to contracting with vendors/subrecipients.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development; U.S. Department of Health and Human Services; U.S. Department of Education Federal Program Name: Continuum of Care Program; National Family Caregiver Support, Title III, Part E; Rehab Services Demonstration & Training Program Assistance Listing Number: 14.267; 93.052; 84.235 Federal Award Identification Number and Year: WA0548L0T002200-2024; DA23-1535-2024; H235F200005-2024 Pass-Through Agency: 14.267-King County Regional Homelessness Authority; 93.052-City of Seattle Pass-Through Number(s): WA0548L0T002200-2024; DA23-1535-2024 Award Period: 1/1/2024-12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Federal Government requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Entity was not able to provide the date the verification check occurring before entering into contract with a vendor/subrecipient. Questioned Costs: None Context: During our testing, we identified instances where there was no documented dates of the verification check occurring before entering into contract with a vendor/subrecipient. Cause: The entity doesn't document the verification check prior to entering into contract with vendor/subrecipient. Effect: The entity is not in compliance with Federal Government requirements. Repeat Finding: No Recommendation: We recommend the entity evaluate its procedures and implement an additional control to document verification checks are occurring prior to entering into contract with a vendor/subrecipient. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Corrective Action Plan

We accept this finding that we could not provide adequate verification or documented dates when an entity is being checked through the Sam.gov system prior to entering into a contract as defined in 2 CFR section 180.995. We have taken steps to correct the issue as of June 1, 2025. All new prospective contractors will be entered into the Sam system and scanned for debarment prior to contracting with them by the Program Manager. In addition, we are in the process of updating our vendor agreements to include language so a vendor can attest they are not debarred from doing business with the federal government.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 572974 2024-001
    Significant Deficiency
  • 572975 2024-001
    Significant Deficiency
  • 572976 2024-002
    Significant Deficiency
  • 1149415 2024-001
    Significant Deficiency
  • 1149416 2024-001
    Significant Deficiency
  • 1149417 2024-001
    Significant Deficiency
  • 1149418 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.235 Rehabilitation Svc Demonstration and Training Programs $387,043
14.267 Multicultural Idd Integrated Support Team Psh $363,427
93.052 National Family Caregiver Support, Title Iii, Part E $305,315
84.328 Special Education Parent Information Centers $197,012
93.630 Community Living $127,333
93.044 Special Programs for Aging, Title Iii, Part B, Grants for Supportive Svcs & Senior Centers $96,702
14.218 Covid-19 Community Development Block Grants/entitlement Grants $80,000
21.027 Covid-19 Special Education Parent Information Centers $67,782
97.024 Emergency Food and Shelter National Board Program $40,000
17.277 Covid-19 Wioa National Disclosed Worker Grants/wia National Emergency Grants $37,893
14.218 Community Development Block Grants/entitlement Grants $20,000
93.590 Community-Based Child Abuse Prevention Grants $10,144
93.566 Refugee and Entrant Assistance State Administered Program $6,653