Finding Text
Missing documentation for procurement, suspension and debarment Audit Results: Information on Federal Programs: Assistance Listing #: 16.582 Crime Victim Assistance/Discretionary Grants and 93.591 Family Violence Prevention and Services/State Domestic Violence Coalitions Grant Award Numbers: VOCA-2018-003, 2001MDSDVC, 2101MDSDVC21, 2001MDSDC3 Federal Agency: United States Department of Justice, United States Department of Health and Human Services. Pass-through Entity (VOCA-2018-003): State of Maryland - Governor's Office of Crime Control and Prevention. Criteria: Per Uniform Guidance 2 CFR 200.318, any contracts procured with federal funds for over $10,000 should be obtained via a bidding process or documentation is required to show that the
contractor is the sole source for the services. In addition, the Organization should keep documentation to show that they have verified that contractors are not suspended or debarred. Condition: Bid or sole source documentation was missing for one contracts and in addition, for that contract, there was no documentation of the verification that the contractor was not suspended or debarred. We consider this to be an instance of non-compliance and a significant deficiency in internal control over compliance for the reporting requirement. Context: It is important to determine that contractors used are eligible for work and that they have not been suspended or debarred from performing work on projects supported by federal funds It is also important to have full and open competition on contract work that is federally funded. Questioned Costs: None Effect: As a result, the Organization is not in compliance with the requirements for procurement, suspension and debarment. Cause: This resulted from human error and turnover at the accounting and management level. Recommendation: Auditors recommend that the Organization maintain all federal award documentation in a location where all authorized personnel have access in order to ensure that it can always be located. We also recommend that management create a process for procurement, including how bids are obtained and maintained for proof of compliance with Uniform Guidance. Management should also establish procedures for verifying that contractors are not suspended or debarred and a
system for maintaining this verification should be established. It is critical to maintain detailed documentation to ensure compliance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: The contract highlighted as part of this audit was a contract that predated FY21 and both the current Executive Director and Finance Manager. As this was not a new contract, no bid or verification that the contractor was not suspended or debarred was conducted during FY21. However, it is understood that this should have been completed in prior years and the fact that there was no documentation to support the completion of this activity is problematic. In order to ensure that proper sole source documentation is in place, MNADV will review all sole source contracts over $10,000 and verify that a bid process is in place and all vendors are properly vetted for suspension or debarment. This will be completed by May 31, 2024.