Finding Text
U.S. Department of Housing and Urban Development
Pass-through Entity: North Carolina Department of Health and Human Services, Division of Aging and Adult Services and City of Charlotte, North Carolina
Program Name: Emergency Solutions Grant
Federal Assistance Listing Number: 14.231
U.S. Department of Treasury
Pass-through Entity: Mecklenburg County, North Carolina
Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Material Weakness; Nonmaterial Noncompliance – Procurement
Finding 2023-003
Criteria: Per Sections 200.318 – 200.327 of the Uniform Grant Guidance, a non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations for the acquisition of property or services required under a Federal award or subaward. Furthermore, a contract award must not be made to suspended or debarred parties listed on the System for Award Management.
Condition: There were two (2) instances out of four (4) contracts tested where the Organization did not properly follow the Uniform Grant Guidance procurement standards for contracted services. The Organization did not check SAM.gov for vendors contracted with that had expenditures over $25,000.
Effect: By not having a policy in line with Uniform Grant Guidance and not performing SAM.gov checks, the Organization could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds.
Cause: The Organization did not obtain quotes from more than one vendor for one contract tested, did not document sole source justification for one contract tested, and did not check SAM.gov for vendors contracted with that had expenditures over $25,000.
Recommendation: The Organization should consider implementing a procurement policy in line with Uniform Grant Guidance including a process to check SAM.gov to ensure a vendor is not suspended or debarred and follow the policy when contracting with new vendors using federal funding.
Views of Management: Management agrees with the finding and is implementing procedures to correct this which are further discussed in the Corrective Action Plan. See Corrective Action Plan for more information.