Finding Text
Federal Agency: U.S. Department of Justice
Federal Program and Assistance Listing Number: Juvenile Mentoring Program, 16.726
Identification Number: 15PJDP-22-AG-04915-MENT
Grant Period: October 1, 2022 – December 31, 2023
2023-003 Procurement and Suspension and Debarment – Significant Deficiency in Internal Control over Compliance
Criteria and Condition: BBBSC must document their procurement process in writing, comply with applicable state and local laws and regulations, and conform to applicable federal statutes and procurement requirements identified in 2 CFR part 200. In addition, BBBSC is prohibited from contracting with parties that are suspended or debarred. Under the guidelines, before contracting with a non-federal entity, the grantee must verify that the non-federal entity is not suspended, debarred, or otherwise excluded from participating in the transaction.
Cause: While policies and procedures were in place and documented in accordance with the Uniform Guidance, the method used by management to procure new services under U.S. Department of Justice funding did not follow all of the required elements. During the course of the audit, it was noted that the appropriate staff check vendors prior to entering into a covered transaction to determine if the vendor is debarred, suspended, or otherwise excluded, but there was no documentation evidencing that verifications were being completed.
Effect: Without following all of the required elements within the written procurement policy, procurements under federal awards may not have been made in compliance with applicable Federal regulations, and covered transaction payments could have been made to parties that were federally suspended, debarred, or otherwise disqualified.
Context: Program expenditures made to certain vendors exceeded either the micro-purchase or covered transaction threshold, triggering the testing of this compliance area during the audit.
Questioned Costs: This finding did not result in any questioned costs.
Identification of Repeat Findings: This is not a repeat finding.
Recommendation: We recommend BBBSC enhance their internal control processes to include all required elements by the Uniform Guidance. Procedures should be included that outline processes and control activities specifically defining oversight of contractors’ performance, which personnel are responsible for each step in the process and who is performing the review over the process, including conflicts of interest and who is responsible for ensuring vendors under covered transactions are not suspended, debarred, or otherwise disqualified.
Views of Responsible Officials and Planned Corrective Actions: BBBSC has updated their procedures to ensure that all required elements under their procurement policy are clearly documented in accordance with Uniform Guidance. Full implementation will occur no later than March 31, 2024.