Finding 589301 (2022-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-05-31

AI Summary

  • Core Issue: The Organization lacks a process to verify vendors and employees against the SAM list, risking inappropriate payments with federal funds.
  • Impacted Requirements: Compliance with 2 CFR, Part 200, which mandates checks for vendors and employees involved in transactions over $25,000.
  • Recommended Follow-Up: Implement a regular verification process against SAM for all relevant vendors and employees, and maintain documentation of these checks.

Finding Text

Finding Number: 2022-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2022 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 20 vendors and 10 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2021-006 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 12858 2022-005
    Material Weakness Repeat
  • 12859 2022-006
    Material Weakness Repeat
  • 12860 2022-007
    Material Weakness Repeat
  • 12861 2022-005
    Material Weakness Repeat
  • 12862 2022-006
    Material Weakness Repeat
  • 12863 2022-007
    Material Weakness Repeat
  • 589300 2022-005
    Material Weakness Repeat
  • 589302 2022-007
    Material Weakness Repeat
  • 589303 2022-005
    Material Weakness Repeat
  • 589304 2022-006
    Material Weakness Repeat
  • 589305 2022-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
64.033 Va Supportive Services for Veteran Families Program $1.18M
14.267 Continuum of Care Program $420,000
14.235 Supportive Housing Program $321,040
14.239 Home Investment Partnerships Program $307,230
64.024 Va Homeless Providers Grant and Per Diem Program $273,040