Finding 972108 (2022-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2024-05-01
Audit: 305283
Organization: Next Move Homeless Services (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The Organization's procurement policy lacks required elements and documentation for compliance with federal suspension and debarment regulations.
  • Impacted Requirements: Noncompliance with 2 CFR 200.303(a) and procurement standards outlined in 2 CFR 200.317-327.
  • Recommended Follow-Up: Develop a compliant written procurement policy and implement documentation procedures for suspension and debarment compliance.

Finding Text

Program: Continuum of Care, Emergency Solutions Grant Program Federal Financial Assistance Listing No.:14.267, 14.231 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward, Sacramento County Department of Human Assistance Award Year: 2022 Compliance Requirement: Procurement, Suspension and Debarment Grant Award Number: CA0955L9T032007, CA0955L9T032108, CA0143L9T032013, CA0143L9T032114, CA1303L9T032006, CA1303L9T032107, DHA-PRTS-NM-06-22, DHA-NM-03-22, DHA-NM-03-23, DHA-NM-08-23, DHA-NM-10-23 Type of Finding: Material Weakness in Internal Controls Over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any contractor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition Found: The Organization’s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the Organization did not retain documentation to support the procedures performed to ensure compliance with suspension and debarment requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/ Sampling: Suspension and debarment was applicable to 13 contractors totaling $1,661,410 under the Continuum of Care Program and six contractors totaling $253,310 under the Emergency Solutions Grant Program. We tested all contractors. Repeat Finding from Prior Years: No. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with suspension and debarment requirements could result in noncompliance with Uniform Guidance. Cause: The Organization does not typically receive federal financial assistance that is subject to procurement and suspension and debarment regulations; consequently, certain elements required by the Uniform Guidance were missing. Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements regarding suspension and debarment. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 395655 2022-002
    Material Weakness Repeat
  • 395656 2022-002
    Material Weakness Repeat
  • 395657 2022-002
    Material Weakness Repeat
  • 395658 2022-002
    Material Weakness Repeat
  • 395659 2022-002
    Material Weakness Repeat
  • 395660 2022-002
    Material Weakness Repeat
  • 395661 2022-003
    Material Weakness
  • 395662 2022-003
    Material Weakness
  • 395663 2022-003
    Material Weakness
  • 395664 2022-003
    Material Weakness
  • 395665 2022-003
    Material Weakness
  • 395666 2022-003
    Material Weakness
  • 395667 2022-003
    Material Weakness
  • 395668 2022-003
    Material Weakness
  • 395669 2022-003
    Material Weakness
  • 395670 2022-003
    Material Weakness
  • 395671 2022-003
    Material Weakness
  • 395672 2022-003
    Material Weakness
  • 972097 2022-002
    Material Weakness Repeat
  • 972098 2022-002
    Material Weakness Repeat
  • 972099 2022-002
    Material Weakness Repeat
  • 972100 2022-002
    Material Weakness Repeat
  • 972101 2022-002
    Material Weakness Repeat
  • 972102 2022-002
    Material Weakness Repeat
  • 972103 2022-003
    Material Weakness
  • 972104 2022-003
    Material Weakness
  • 972105 2022-003
    Material Weakness
  • 972106 2022-003
    Material Weakness
  • 972107 2022-003
    Material Weakness
  • 972109 2022-003
    Material Weakness
  • 972110 2022-003
    Material Weakness
  • 972111 2022-003
    Material Weakness
  • 972112 2022-003
    Material Weakness
  • 972113 2022-003
    Material Weakness
  • 972114 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.267 Continuum of Care Program $1.01M
93.558 Temporary Assistance for Needy Families $654,000
14.218 Covid-19 Community Development Block Grants/entitlement Grants $363,383
14.231 Covid-19 Emergency Solutions Grant Program $317,875
14.218 Community Development Block Grants/entitlement Grants $184,908
14.231 Emergency Solutions Grant Program $148,987
97.024 Emergency Food and Shelter National Board Program $67,637
10.558 Child and Adult Care Food Program $63,454