Finding 585032 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-01-16
Audit: 11626
Organization: Asylum Access (CA)

AI Summary

  • Core Issue: Asylum Access lacks documented procurement procedures, leading to noncompliance with federal regulations.
  • Impacted Requirements: CFR 200.318 and CFR 200.320(c) require proper documentation and justification for procurement processes.
  • Recommended Follow-Up: Establish a procurement policy and train staff to ensure compliance with federal guidelines.

Finding Text

Finding 2023-001: Procurement Information on the Federal Programs: Assistance Listing Number 19.511 and 19.518 Criteria: CFR 200.318 states that non-Federal entities must have and use documented procurement procedures consistent with the requirements for procurement regulations included in paragraphs 318 through 327. Condition: During our audit, we noted multiple instances where vendors were engaged without a complete set of documentation supporting a procurement process, or justification to support using a noncompetitive procurement process in accordance with CFR 200.320(c). Cause: Asylum Access does not maintain documented policies regarding procurement and therefore compliance with Federal regulations cannot be determined. Context: Absent a policy related to compliance with CFR 200, Asylum Access is at risk of entering into contracts for goods or services under Federal awards that were not adequately procured based on the regulations in the Uniform Guidance and the awarding agency or pass-through entity could disallow the costs paid for the goods or services. Effect: Asylum Access may have disallowed costs for not properly procuring goods or services. Questioned Costs: None noted. Identification as a Repeat Finding: N/A Recommendation: We recommend Asylum Access establish a procurement policy to become compliant with CFR 200. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 8589 2023-001
    Significant Deficiency
  • 8590 2023-001
    Significant Deficiency
  • 8591 2023-001
    Significant Deficiency
  • 8592 2023-002
    Significant Deficiency
  • 8593 2023-001
    Significant Deficiency
  • 8594 2023-002
    Significant Deficiency
  • 585031 2023-001
    Significant Deficiency
  • 585033 2023-001
    Significant Deficiency
  • 585034 2023-002
    Significant Deficiency
  • 585035 2023-001
    Significant Deficiency
  • 585036 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $1.25M
19.511 Overseas Refugee Assistance Programs for East Asia $408,532