Finding 618158 (2022-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: The Association failed to verify vendors against the SAM for transactions over $25,000, risking non-compliance with federal requirements.
  • Impacted Requirements: Compliance with 2 CFR, Part 200, which mandates checking for vendor suspension or debarment before engaging in covered transactions.
  • Recommended Follow-Up: Establish a process to annually verify all qualifying vendors against the SAM and document these checks, especially for new vendors.

Finding Text

Finding Number: 2022-001 Information on the Federal Program: Federal Agency: U.S. Department of Transportation Program Name: Formula Grants for Rural Areas and Tribal Transit Programs AL: 20.509; Federal Award Identification Number: 04-96-96-964010-2916-072-500575 Federal Award Year: Year Ended June 30, 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 or employee 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: During our audit, we noted the Association did not review the SAM for vendors meeting the covered transaction threshold. Context: Based on our testing, we noted that none of the 4 vendors selected in our testing that were charged to the grant were included in the SAM listing. Although we did note the Association has a process to review employees upon hire and on a monthly basis to the SAM.gov listing, this review does not occur for vendors. Questioned Costs: None. Cause and Effect: The Association was unaware of the requirement to verify vendors against the SAM. Since this process was not performed on vendors, there was a risk that vendors who may be included on the SAM were included in this federal program. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend the Association implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Association 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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 41716 2022-001
    Material Weakness
  • 41717 2022-002
    Material Weakness
  • 41718 2022-002
    Material Weakness
  • 41719 2022-002
    Material Weakness
  • 618159 2022-002
    Material Weakness
  • 618160 2022-002
    Material Weakness
  • 618161 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
20.509 Formula Grants for Rural Areas and Tribal Transit Program $421,793
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $265,263
93.558 Temporary Assistance for Needy Families $161,428
93.055 Pphf - Applied Leadership for Community Health Improvement $126,462
93.667 Social Services Block Grant $67,385
93.053 Nutrition Services Incentive Program $55,446
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $24,723
93.556 Promoting Safe and Stable Families $19,551
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $9,573
93.994 Maternal and Child Health Services Block Grant to the States $5,221
93.645 Stephanie Tubbs Jones Child Welfare Services Program $3,974
10.558 Child and Adult Care Food Program $1,032