Finding 7786 (2022-004)

Material Weakness
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2024-01-08
Audit: 10124
Organization: Televerde Foundation, Inc. (AZ)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The Foundation lacks proper internal controls over federal awards, leading to potential noncompliance with procurement standards.
  • Impacted Requirements: Failure to conduct price analysis, ensure open competition, and check for vendor suspension or debarment violates CFR 200.303(a) and 2 CFR 200.318-327.
  • Recommended Follow-Up: Implement and document procurement procedures, including checks for vendor eligibility, to ensure compliance and avoid improper expenses.

Finding Text

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022, Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Foundation is managing the federal award in compliance with federal statutes, regulations and terms and conditions of the federal award. The non‐Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.318 through 200.327 which also requires documentation to be retained to detail the history of procurements. In addition, as outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The Foundation did not retain documentation to support performance a price analysis nor provide the opportunity for open competition. Additionally, the Foundation did not review for suspension or debarment and required contract provisions were not followed. Cause: The Organization has limited staffing and did not have proper controls in place relating to review of procurement. Effect: Improper expenses may be paid and charged to the federal program and covered transactions could be potentially entered into with suspended or debarred parties. Questioned Costs: Questioned costs were unable to be determined. Context: A nonstatistical sample of 12 transactions out of 60 total transactions were selected for testing totaling $148,605 of $275,567 procurement expenditures. Repeat Finding from Prior Years: No Recommendation: We recommend the Foundation follow designed control processes which includes performing required procurement procedures and maintaining within the procurement file documentation of a review to ensure the party to the covered transaction is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation did not retain documentation to support performance of a price analysis nor provide the opportunity for open competition. Additionally, the Foundation did not review for suspension or debarment and required contract provisions were not followed. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will retain and catalog documentation related to price quotes for certain Foundation expenditures. We will update our procurement policy to be consistent with federal guidelines to assist in streamlining the procurement process. We have hired a Grant Administrator and Analyst who is responsible for reviewing contractors against the System for Award Management for suspension or debarment, including subrecipients. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: January 2024

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 7787 2022-005
    Material Weakness
  • 7788 2022-006
    Material Weakness
  • 7789 2022-007
    Material Weakness
  • 584228 2022-004
    Material Weakness
  • 584229 2022-005
    Material Weakness
  • 584230 2022-006
    Material Weakness
  • 584231 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $640,075
17.270 Reintegration of Ex-Offenders $298,692