Finding 598212 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-11-14
Audit: 27933
Organization: Archdiocese of St. Louis (MO)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: Procurement processes for federal grants did not follow required guidelines, leading to potential noncompliance.
  • Impacted Requirements: 2 CFR section 200.3018 mandates documented procurement procedures and compliance controls for federal grants.
  • Recommended Follow-Up: Management should document procurement policies, conduct training for staff, and implement a compliance checklist to ensure adherence to guidelines.

Finding Text

Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 21768 2022-003
    Significant Deficiency
  • 21769 2022-003
    Significant Deficiency
  • 21770 2022-003
    Significant Deficiency
  • 21771 2022-003
    Significant Deficiency
  • 21772 2022-003
    Significant Deficiency
  • 21773 2022-003
    Significant Deficiency
  • 21774 2022-003
    Significant Deficiency
  • 21775 2022-003
    Significant Deficiency
  • 21776 2022-003
    Significant Deficiency
  • 21848 2022-003
    Significant Deficiency
  • 21849 2022-003
    Significant Deficiency
  • 21850 2022-002
    Material Weakness
  • 21851 2022-004
    Significant Deficiency
  • 21912 2022-002
    Material Weakness
  • 21913 2022-004
    Significant Deficiency
  • 21914 2022-004
    Significant Deficiency
  • 21915 2022-002
    Material Weakness
  • 598210 2022-003
    Significant Deficiency
  • 598211 2022-003
    Significant Deficiency
  • 598213 2022-003
    Significant Deficiency
  • 598214 2022-003
    Significant Deficiency
  • 598215 2022-003
    Significant Deficiency
  • 598216 2022-003
    Significant Deficiency
  • 598217 2022-003
    Significant Deficiency
  • 598218 2022-003
    Significant Deficiency
  • 598290 2022-003
    Significant Deficiency
  • 598291 2022-003
    Significant Deficiency
  • 598292 2022-002
    Material Weakness
  • 598293 2022-004
    Significant Deficiency
  • 598354 2022-002
    Material Weakness
  • 598355 2022-004
    Significant Deficiency
  • 598356 2022-004
    Significant Deficiency
  • 598357 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.12M
14.181 Supportive Housing for Persons with Disabilities $1.02M
16.575 Crime Victim Assistance $522,133
14.235 Supportive Housing Program $400,000
21.023 Covid-19 - Emergency Rental Assistance Program $381,664
17.805 Homeless Veterans Reintegration Project $336,612
93.778 Medical Assistance Program $328,833
14.267 Continuum of Care Program $264,408
93.558 Temporary Assistance for Needy Families $181,026
94.011 Foster Grandparent Program $176,974
14.231 Emergency Solutions Grant Program $161,750
21.019 Covid-19 - Coronavirus Relief Fund $119,955
14.218 Covid - 19 - Community Development Block Grants/entitlement Grants $100,000
93.498 Covid-19 - Provider Relief Fund $95,890
10.555 National School Lunch Program $85,920
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $82,024
10.565 Commodity Supplemental Food Program $79,651
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $76,695
14.218 Community Development Block Grants/entitlement Grants $75,000
64.033 Covid-19 - Va Supportive Services for Veteran Families Program $71,329
64.024 Va Homeless Providers Grant and Per Diem Program $63,544
14.195 Section 8 Housing Assistance Payments Program $60,193
10.553 School Breakfast Program $34,733
14.231 Covid - 19 - Emergency Solutions Grant Program $26,250
14.U01 Demonstration Grant of 1993 $25,000
10.558 Child and Adult Care Food Program $23,825
14.169 Housing Counseling Assistance Program $23,257
16.588 Violence Against Women Formula Grants $22,864
97.024 Emergency Food and Shelter National Board Program $8,465
10.582 Fresh Fruit and Vegetable Program $6,613
16.524 Legal Assistance for Victims $5,990
93.350 National Center for Advancing Translational Sciences $5,000
14.921 Older Adults Home Modification Grant Program $4,877
17.225 Covid-19 - Unemployment Insurance $4,378
10.556 Special Milk Program for Children $849