Finding Text
2023 – 001 Procurement – Suspension and Debarment
Federal agency: Federal Emergency Management Agency
Federal program title: Fund for Emergency Food and Shelter Program
Federal Assistance Listing Number: 97.024
Award Period: June 1, 2022 – December 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and
debarment. United Way of the National Capital Area should have internal controls designed to ensure
compliance with those provisions and follow suspension and debarment procedures before entering into the
transaction.
Condition: During our testing, we noted United Way of the National Capital Area did not have documentation to
support that internal controls were performed to ensure vendor and subrecipient were not suspended or
debarred prior to entering into the first transaction. Additionally, the compliance check for one out of two
vendors was not performed before the first transaction with the vendor.
Questioned costs: None
Context: During our testing, it was noted that for one of two vendors tested United Way of the National Capital
Area did not have documentation to support that it had reviewed a subrecipient prior to entering into a contract
with a subrecipient to ensure a subrecipient was not on the suspended or debarred organization list maintained
by the General Services Administration. During our testing, it was also noted that for 1 of 2 items tested that
United Way of the National Capital Area did not perform the vendor review procedures prior to the first
transaction. We verified that these selected subrecipient and vendor were not suspended or debarred.
Cause: United Way of the National Capital Area was unable to locate documentation to support the
performance of procedures to ensure a subrecipient were not suspended or debarred. In addition, United Way
of the National Capital Area did not perform the search for suspension and debarment prior to the first
transaction.
Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and
debarment; however, the lack of internal controls over these compliance requirements provides an opportunity
for noncompliance.
Recommendation: We recommend United Way of the National Capital Area design controls to ensure an
adequate review process is in place to review potential vendor and subrecipient to determine they are not
suspended or debarred and to ensure documentation to support this is maintained. We also recommend that
the search for suspension and debarment is performed prior to entering the first transaction.
Views of responsible officials: There is no disagreement with the audit finding.