Finding 964865 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The Organization failed to use a formal procurement method for a vendor paid over the Simplified Acquisition Threshold, violating federal guidelines.
  • Impacted Requirements: Section §200.320 of the Uniform Guidance mandates formal procurement methods, including public advertising, for significant purchases.
  • Recommended Follow-Up: Implement regular training for staff on procurement rules and enhance internal controls to ensure compliance with procurement policies.

Finding Text

Procurement (Significant Deficiency) and Compliance Federal Agency: U.S. Department of Homeland Security Program Title: Emergency Food & Shelter National Board Program (“EFSP”) Assistance Listing Number: 97.024 Federal Award Source: Pass-through funding Pass-Through Entity: Pima County Pass-Through Identifying Number: CT-GMI-21-452 Criteria – Section §200.320 of the Uniform Guidance requires that when the value of the procurement for property or services under a Federal financial assistance award exceeds the Simplified Acquisition Threshold, a formal procurement method is required, such as a sealed bid or proposal. In addition, these formal procurement methods require public advertising. Condition – During our audit of the procurement requirements for the EFSP program, we noted the Organization utilized a vendor who in total was paid more than the Simplified Acquisition Threshold; however, the Organization did not utilize a formal procurement method in selecting this vendor as required by their policies and the Uniform Guidance. Cause – The finding appears to be the result of an immediate need to obtain services and an oversight to subsequently conduct a formal procurement method. Effect and Context – By not adhering to a formal procurement method, the Organization may or may not have chosen the best vendor to provide the services. There was only one vendor whose payments exceeded the Simplified Acquisition Threshold during the audit period. Our sample was a statistically valid sample. Questioned Costs – None noted. Recommendation – We recommend the Organization provide periodic training to its program staff regarding procurement requirements per the Uniform Guidance and consider modifying its procurement related internal controls to ensure all staff follow the Organization’s procurement policies. View of Responsible Officials: We are in agreement with the finding and are in the process of updating our procedures to mitigate issues in the future. See our Corrective Action Plan for the fiscal year ended June 30, 2023 for additional detail.

Categories

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 388423 2023-001
    Significant Deficiency
  • 388424 2023-002
    Significant Deficiency
  • 964866 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
97.024 Emergency Food and Shelter National Board Program $5.69M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $2.54M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.51M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.03M
93.560 Family Support Payments to States_assistance Payments $218,213
19.510 U.s. Refugee Admissions Program $207,364
93.575 Child Care and Development Block Grant $203,034
93.053 Nutrition Services Incentive Program $201,047
93.576 Refugee and Entrant Assistance_discretionary Grants $149,376
93.667 Social Services Block Grant $132,862
93.052 National Family Caregiver Support, Title Iii, Part E $130,584
21.008 Low Income Taxpayer Clinics $104,017
93.558 Temporary Assistance for Needy Families $89,614
21.027 Coronavirus State and Local Fiscal Recovery Funds $87,920
14.231 Emergency Solutions Grant Program $77,729
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $76,805
93.570 Community Services Block Grant_discretionary Awards $69,990
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $60,773
16.575 Crime Victim Assistance $55,179
14.239 Home Investment Partnerships Program $52,483
97.067 Homeland Security Grant Program $51,817
14.218 Community Development Block Grants/entitlement Grants $51,603
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $40,734
10.558 Child and Adult Care Food Program $31,750
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $143