FAC Explorer

Finding 59651 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-07-16
Audit: 55049
Organization: Coos Watershed Association (OR)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: Internal controls were missing to check for suspended or debarred entities before transactions.
  • Impacted Requirements: Compliance with Uniform Guidance for procurements was not met.
  • Recommended Follow-Up: Update policies to include checks on www.sam.gov for all covered transactions.

Finding Text

Funding Agency: Department of Commerce Program: Habitat Conservation Assistance Listing Number: 11.463 Criteria or Specific Requirement: Internal controls should be implemented to ensure procurements subject to the Uniform Guidance included procedures to ensure covered transactions are not entered into with entities suspended or debarred from receiving federal funding. Condition: Internal controls were not in place to perform a check on www.sam.gov for an entity?s suspension or debarment status prior to entering into the covered transactions. Context: For covered transactions no procurement or debarment check was performed by management prior to entering into the transaction. Management performed a check during the audit and verified the Organization did not enter into a covered transaction with a suspended or debarred entity. Questioned Costs: None Cause/Effect:. The Organization could enter into a covered transaction with an entity that is suspended or debarred from receiving federal funding. Recommendation: CLA recommends the Organization updated its policies and procedures to include the check on www.sam.gov for entities it intends to enter into a covered transaction with. View of Responsible Official: Management agrees with the finding and has provided its corrective action plan.

Corrective Action Plan

RE: Management Corrective Action Letter - FY2022 Federal Single Audit: Significant Deficiency in Internal Controls - Procurement, Suspension and Debarment To Whomever it May Concern, This letter is in response to Clifton Larson Allen LLP finding of "Significant Deficiency in Internal Controls - Procurement, Suspension and Debarment" in their federal single audit of our organization's 2022 fiscal year Upon notification of this finding, Coos Watershed Association (Association) management immediately drafted a revision to our fiscal policy to include a policy and procedure for ensuring that covered transactions are not entered into with entities suspended or debarred from receiving federal funding. This policy was approved by the Board of Directors on March 14th, 2023 and is included below. Coos Watershed Association Fiscal Policy Section 7b, page 16: "If the Contract is being paid for with federal funding, the Executive Director will ensure that the selected Contractor is not suspended or debarred from doing business with federal contracts by conducting an exclusion search on sam.gov before entering into the Contract. The Association will not enter into Contracts with Contractors who are not legally allowed to work on state or federal contracts." Additionally, the Executive Director performed an exclusion search and found that all contractors working for the Association on covered transactions are not excluded from working on federal contracts.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 59652 2022-001
    Significant Deficiency
  • 59653 2022-001
    Significant Deficiency
  • 59654 2022-001
    Significant Deficiency
  • 636093 2022-001
    Significant Deficiency
  • 636094 2022-001
    Significant Deficiency
  • 636095 2022-001
    Significant Deficiency
  • 636096 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.463 Habitat Conservation $49,940
15.243 Youth Conservation Opportunities on Public Lands $49,293
15.230 Invasive and Noxious Plant Management $36,711
10.931 Agricultural Conservation Easement Program $22,242
15.246 Threatened and Endangered Species $20,704
10.U03 US Forest Service $20,540
10.U02 US Forest Service $12,219
10.U04 US Forest Service $10,468
15.234 Secure Rural Schools and Community Self-Determination $9,546
15.654 National Wildlife Refuge System Enhancements $5,839
11.438 Pacific Coast Salmon Recovery_pacific Salmon Treaty Program $4,443
15.244 Fisheries and Aquatic Resources Management $4,215
10.U01 US Forest Service $1,319
15.245 Plant Conservation and Restoration Management $21