Finding 59139 (2022-003)

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Requirement
I
Questioned Costs
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Year
2022
Accepted
2023-04-20

AI Summary

  • Core Issue: The Organization has not implemented the required procurement procedures outlined in the Uniform Guidance.
  • Impacted Requirements: Compliance with federal regulations for procurement is lacking, which could affect funding eligibility.
  • Recommended Follow-up: Review and implement the Uniform Guidance procurement requirements, and have a qualified public accountant verify compliance.

Finding Text

Finding 2022-003: Federal Grants Procedures Manual (Uniform Guidance Compliance) Criteria On May 17, 2017, the Office of Management and Budget (OMB) issued an addendum to Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) allowing nonfederal entities an additional year to implement the Uniform Guidance procurement requirements and the entity must document the decision to utilize the extension. Condition The Organization has not implemented the Uniform Guidance procurement requirements. Cause Organization management was not aware of the Uniform Guidance requirements and implementation dates. Effect The Organization's procurement policies and procedures are not in compliance with the Uniform Guidance. Recommendation We recommend the Organization review the Uniform Guidance procurement requirements and implement the requirements. Views of Responsible Officials The Organization agrees with the Auditor's findings. We will implement the Uniform Guidance procurement requirements as issued by the Office of Management and Budget (OMB). We will also have the process reviewed by a qualified public accountant to make sure it complies with the regulations set forth.

Corrective Action Plan

Finding 2022-003: Federal Grants Procedures Manual (Uniform Guidance Compliance) The Chief Executive Officer, Administrative Officer will work with the Accounting Officer to implement the Uniform Guidance procurement requirements as issued by the Office of Management and Budget (OMB). We will also have the process reviewed by a qualified public accountant to make sure it complies with the regulations set forth. To address these findings and ensure compliance with Title 2 requirements, Habitat for Humanity Yuba/Sutter will implement the following corrective action plan: 1. Operationalize the Grants Management Standards ? Habitat for Humanity Yuba/Sutter will conduct a comprehensive review of its current grants management policies and procedures to identify any gaps or deficiencies in compliance with Title 2 requirements. ? The organization will update its grants management policies and procedures to align with Title 2 regulations, including documentation requirements, financial management, reporting, and record keeping. ? Habitat for Humanity Yuba/Sutter will provide training and resources to its staff involved in grants management to ensure they are knowledgeable about the updated policies and procedures. ? The organization will establish a system for ongoing monitoring and internal audits to ensure compliance with grants management standards, and make necessary adjustments as needed. 2. Establish a Robust Marketplace of Modern Solutions ? Habitat for Humanity Yuba/Sutter will conduct a thorough review of its current marketplace of solutions, including vendors, software, and technologies used in its operations. ? The organization will identify opportunities to modernize its systems and processes to enhance efficiency, streamline operations, and ensure compliance with Title 2 requirements. ? Habitat for Humanity Yuba/Sutter will develop a plan to implement modern solutions, including budgeting, procurement, and implementation timelines. ? The organization will establish a process for ongoing evaluation and monitoring of the effectiveness of the modern solutions implemented, and make necessary adjustments as needed. 3. Manage Risk ? Habitat for Humanity Yuba/Sutter will conduct a comprehensive risk assessment to identify potential risks associated with grants management and compliance with Title 2 requirements. ? The organization will develop and implement risk mitigation strategies, including internal controls, monitoring mechanisms, and contingency plans. ? Habitat for Humanity Yuba/Sutter will establish a system for ongoing risk management, including regular risk assessments and reviews, and updates to risk mitigation strategies as needed. ? The organization will ensure that all staff involved in grants management are aware of the risk mitigation strategies and trained on how to implement them effectively. 4. Achieve Program Goals and Objectives ? Habitat for Humanity Yuba/Sutter will review and align its program goals and objectives with the requirements of Title 2. ? The organization will develop a comprehensive plan to ensure that its programs are designed, implemented, and evaluated in accordance with Title 2 guidelines, including outcome measurement, data collection, and reporting. ? Habitat for Humanity Yuba/Sutter will establish regular monitoring and reporting mechanisms to track progress towards program goals and ensure compliance with Title 2 requirements. ? The organization will provide training and resources to its staff involved in program management to ensure they are knowledgeable about the updated program goals and objectives and the requirements of Title 2.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.019 Coronavirus Relief Fund $580,313
14.231 Emergency Solutions Grant Program $48,725
93.569 Community Services Block Grant $46,786
14.218 Community Development Block Grants/entitlement Grants $30,000
14.252 Section 4 Capacity Building for Community Development and Affordable Housing $6,960