Finding 576235 (2024-002)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-12
Audit: 366160
Organization: Opening Doors, Inc. (CA)

AI Summary

  • Core Issue: The organization failed to verify vendor suspension or debarment status before entering contracts, leading to potential compliance risks.
  • Impacted Requirements: This finding affects compliance with 2 CFR 200.403(a), which mandates verification of vendor eligibility in covered transactions.
  • Recommended Follow-Up: Strengthen policies to ensure vendor suspension and debarment checks are consistently performed prior to contract agreements.

Finding Text

Federal Agency: U.S. Department of Health & Human Services Federal Program Name: Refugee and Entrant Assistance Voluntary Agency Programs Assistance Listing Number: 93.576 Federal Award Identification Number and Year: Various, see below Pass-Through Agency: Various, see below Pass-Through Number: Various, see below Award Period: Various, see below Compliance Requirement Affected: Suspension & Debarment Direct Agency Direct Award number Award Period Pass Through Entity (or) Pass Through Number U.S. Department of Health & Human Services (Direct) 90RG0243-01-00 10/1/2023-9/30/2024 90RG0225-01-00 10/1/2022-9/29/2025 90ZI0174-01-00 9/30/2023-09/29/2027 Passed through California Department of Social Services N/A 10/1/2023-9/30/2024 Passed through Los Rios Community College District N/A 9/30/2022-9/29/2025 Passed through Church World Services CWS-2024-04-015 10/1/2023-9/30/2024 CWS-2024-10-017 10/1/2024-9/30/2025 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.403(a) - 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: During our single audit procedures, 100% of our suspension and debarment samples selected did not contain sufficient documentation detailing the Organization’s process for determining the vendor was not suspended nor debarred prior to participating in the transaction. Context: A nonstatistical sample of 6 out of 21 vendors were selected for testing for the Refugee and Entrant Assistance Voluntary Agency Programs program. The condition noted above was identified during our procedures over ODI's Suspension and Debarment. Effect: ODI did not verify suspension or debarment status, which could result in entering into a contract with a vendor, which is potentially suspended or debarred. Cause: ODI did not consistently ensure that Suspension or Debarment status was verified before entering into agreements with the vendors. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that ODI strengthen its current policies and procedures to ensure that Suspension and Debarment Status is verified for vendors subject to verification according to ODI's Procurement policy, prior to entering into a contract with the vendor. Management’s Views: Management notes that debarment checks performed post transactions confirmed that no vendors were suspended or debarred. Management takes responsibility for the finding and believes that in future years, they will be able to implement proper controls to mitigate this finding.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 576233 2024-002
    Material Weakness
  • 576234 2024-003
    Material Weakness
  • 576236 2024-003
    Material Weakness
  • 576237 2024-002
    Material Weakness
  • 576238 2024-003
    Material Weakness
  • 576239 2024-002
    Material Weakness
  • 576240 2024-003
    Material Weakness
  • 576241 2024-002
    Material Weakness
  • 576242 2024-003
    Material Weakness
  • 576243 2024-002
    Material Weakness
  • 576244 2024-003
    Material Weakness
  • 576245 2024-004
    Significant Deficiency
  • 1152675 2024-002
    Material Weakness
  • 1152676 2024-003
    Material Weakness
  • 1152677 2024-002
    Material Weakness
  • 1152678 2024-003
    Material Weakness
  • 1152679 2024-002
    Material Weakness
  • 1152680 2024-003
    Material Weakness
  • 1152681 2024-002
    Material Weakness
  • 1152682 2024-003
    Material Weakness
  • 1152683 2024-002
    Material Weakness
  • 1152684 2024-003
    Material Weakness
  • 1152685 2024-002
    Material Weakness
  • 1152686 2024-003
    Material Weakness
  • 1152687 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.510 U.s. Refugee Admissions Program $4.96M
93.576 Refugee and Entrant Assistance Discretionary Grants $1.98M
14.267 Continuum of Care Program $613,649
93.569 Community Services Block Grant $74,961
59.046 Microloan Program $64,444
21.020 Community Development Financial Institutions Program $16,108