Finding 634979 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-02-13
Audit: 55324
Organization: Holy Cross Services, Inc. (MI)
Auditor: Doeren Mayhew

AI Summary

  • Core Issue: The Organization is not checking the SAM Excluded Parties Listing before contracting with vendors, risking engagement with suspended or debarred parties.
  • Impacted Requirements: This violates 2 CFR §180, which prohibits contracts over $25,000 with suspended or debarred entities.
  • Recommended Follow-Up: Establish formal procedures to verify vendor status against the SAM list before procurement and conduct annual reviews for recurring vendors.

Finding Text

SECTION III FEDERAL AWARD AUDIT FINDINGS 2022-001 Finding Type Significant Deficiency Federal Program Emergency Solutions Grant Program, ALN #14.231 Criteria Pursuant to 2 CFR ?180, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Covered transactions include contracts for goods and services that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Condition During our testing, we noted that the Organization does not review the System for Award Management?s (SAM) Excluded Parties Listing prior to engaging in covered transactions with vendors. Cause There are no formal policies or procedures in place to review the SAM Excluded Parties Listing prior to procuring goods and services from vendors. Effect The Organization is at risk of procuring goods or services from a vendor that has been suspended or debarred by the Federal government. This could result in significant questioned costs. Identification of a Repeat Finding This is not a repeat finding from the prior year?s audit. Questioned Costs None. Recommendation We recommend management establish procedures to ensure that suspension and debarment exclusion verifications are performed prior to engaging in covered transactions with vendors. These procedures should include reviewing the SAM Excluded Parties Listing prior to adding a new vendor to the accounting system, as well as annually for any recurring vendors with procurement transactions equaling or exceeding $25,000. Response Management will implement a new policy to ensure that suspension and debarment exclusion verifications are performed prior to engaging in covered transactions with vendors.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 58535 2022-001
    Significant Deficiency
  • 58536 2022-001
    Significant Deficiency
  • 58537 2022-001
    Significant Deficiency
  • 58538 2022-001
    Significant Deficiency
  • 634977 2022-001
    Significant Deficiency
  • 634978 2022-001
    Significant Deficiency
  • 634980 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
64.024 Va Homeless Providers Grant and Per Diem Program $615,570
14.231 Emergency Solutions Grant Program $323,370
21.023 Emergency Rental Assistance Program $89,889
93.558 Temporary Assistance for Needy Families $69,974
14.267 Continuum of Care Program $32,766
84.027 Special Education_grants to States $32,617
10.553 School Breakfast Program $18,272