Finding Text
Department of Housing and Urban Development
Continuum of Care, Federal Financial Assistance Listing 14.267
Department of the Treasury
Coronavirus State and Local Fiscal Recovery Funds Program, Federal Financial Assistance Listing 21.027
Procurement, Suspension, and Debarment
Material Weakness in Internal Control Over Compliance and Other Compliance
Grant Award Number: Affects all grant awards included under Federal Financial Assistance Listing/CFDA 14.267 and 21.027 on the Schedule.
Criteria: 2 CFR Part 200 (Uniform Guidance) requires that a non-federal entity must use its own documented procurement, suspension, and debarment procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards.
Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards; however, the procedures were not followed regarding maintaining documentation of obtaining quotes for simplified acquisition small purchases and the conclusion as to which item was selected. In addition, Catholic Charities was not testing vendors for suspension and debarment.
Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy were followed as well as the suspension and debarment.
Effect: The best price for the purchase may not have been obtained and payments could be made to recipients who were suspended or debarred.
Questioned Costs: None reported.
Context/Sampling: For Federal Financial Assistance Listing 14.267, a nonstatistical sample of
32 transactions out of 159 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension and debarment. For Federal Financial Assistance Listing 21.027, a nonstatistical sample of 22 transactions out of 110 total transactions were selected for testing. Required documentation related to procurement was not maintained for one of the items selected, and two of the items selected did not have support for suspension, and debarment.
Repeat Finding from Prior Years: Yes
Recommendation: We recommend Catholic Charities enhance internal control to ensure all transactions under federal awards follow their written procurement policy, and suspension and debarment verification procedures are performed prior to entering into the transactions.
Views of Responsible Officials: Management is in agreement with this finding.