Finding 573509 (2024-002)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-13
Audit: 364224
Organization: Engineers Without Borders USA (CO)

AI Summary

  • Core Issue: EWB-USA failed to maintain necessary records for vendor procurement and suspension/debarment checks.
  • Impacted Requirements: Non-compliance with Title 2 U.S. Code of Federal Regulations, specifically regarding procurement documentation.
  • Recommended Follow-Up: Implement new procurement procedures and train staff to ensure proper documentation and compliance with federal regulations.

Finding Text

Finding 2024-002: 10.761 - U.S. Department of Agriculture - Water and Waste Technical Assistance and Training - Material Weakness Compliance Requirement: Procurement and Suspension and Debarment Criteria: Per Title 2 U.S. Code of Federal Regulations (CPR) Part 200, Subpart D, section 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of procurement and suspension and debarment. Condition: During our testing of internal controls over compliance related to procurement and suspension and debarment, we identified vendors/ contractors that were awarded without required procurement and suspension and debarment documentation. Although there was no documentation to support this verification being performed prior to the payment, we noted that the vendors/contractors were not suspended or debarred. Questioned Costs: None. Cause: EWB-USA did not have adequate controls in place to ensure compliance with applicable federal requirements. Effect: EWB-USA was not in compliance with the procurement and suspension and debarment provisions as prescribed in the CFR. Recommendation: We recommend that EWB-USA implement procedures and controls to ensure that the approval of contractors or vendors are adequately supported by sufficient documentation and detail. In addition, this documentation should be retained, at a minimum, through the completion of the contract. Response: 1. Develop procurement procedures for procurement transactions under Federal awards or subawards, including verification that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. 2. Provide training to relevant staff on the new procedures for procurement transactions including the verification of suspension and debarment for any subrecipient awards and the importance of compliance with federal regulations.

Corrective Action Plan

Corrective Action: 1. Develop procurement procedures for procurement transactions under Federal awards or subawards, including verification that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. 2. Provide training to relevant staff on the new procedures for procurement transactions, including the verification of suspension and debarment for any subrecipient awards and the importance of compliance with federal regulations.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 573510 2024-003
    Material Weakness
  • 573511 2024-004
    Material Weakness
  • 573512 2024-005
    Material Weakness
  • 573513 2024-002
    Material Weakness
  • 573514 2024-003
    Material Weakness
  • 573515 2024-004
    Material Weakness
  • 573516 2024-005
    Material Weakness
  • 1149951 2024-002
    Material Weakness
  • 1149952 2024-003
    Material Weakness
  • 1149953 2024-004
    Material Weakness
  • 1149954 2024-005
    Material Weakness
  • 1149955 2024-002
    Material Weakness
  • 1149956 2024-003
    Material Weakness
  • 1149957 2024-004
    Material Weakness
  • 1149958 2024-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
66.309 Surveys, Studies, Investigations, Training and Special Purpose Activities Relating to Environmental Justice $202,837
20.942 Thriving Communities Program Capacity Builders Cooperative Agreements $65,955
10.761 Water and Waste Technical Assistance and Training Grants $5,806