National Council for Community DevelopmentNon-Profit

Finding No. 2024-001 - Procurement, Suspension and Debarment - Significant Deficiency Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available Name of Pass-through Entity (if applicable): City of Irving Criteria In accordance with §200.214 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition During our testing, we noted that the Organization did not provide adequate supporting documentation for ensuring proper suspension and debarment checks were performed. Cause The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the suspension and debarment requirements. Effect or Potential Effect Failure to timely verify that a recipient is not suspended or debarred could result in the Organization funding a person or entity that is barred from performing work for the U.S. government. Questioned Costs N/A Context For 3 suspension and debarment samples out of a total of 25 tested, management did not provide adequate supporting documentation for ensuring proper suspension and debarment checks were performed. None of the 3 samples were suspended or debarred. Identification as a Repeat Finding This finding is a repeat finding, see prior year finding number: 2023-002. Recommendation We recommend that the Organization establish written suspension and debarment policies and procedures to ensure that the Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials We will incorporate procedures in our grant compliance and administration policies and procedures that include appropriate searches for suspension and debarment prior to executing any financial transactions with covered persons

Finding No. 2024-002 - Reporting - Significant Deficiency Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available Name of Pass-through Entity (if applicable): Nassau County Criteria In accordance with §200.300, nonfederal entities are responsible for complying with all requirements of the Federal award. The Memorandum of Understanding between Nassau County and the Organization requires management to submit quarterly financial and performance reports. Condition During our testing, we noted that the Organization did not provide the one of the required quarterly reports to the Nassau County. Cause The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the requirements regarding reporting. Effect or Potential Effect Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance with laws and regulations. Questioned Costs None Context For 1 report samples out of a total of 14 tested, management did not submit the required reports. Identification as a Repeat Finding This finding is a repeating, see prior year finding number: 2023-003. Recommendation We recommend that the Organization establish policies, procedures, and controls to ensure that the required information is submitted on a timely basis. Views of Responsible Officials We will incorporate procedures in our grant compliance and administration policies and procedures that include a review and understanding of the reporting requirements

Finding No. 2023-002 - Procurement, Suspension and Debarment - Material Weakness Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available Name of Pass-through Entity (if applicable): City of Seattle, City of Scranton Criteria In accordance with §200.214 and §180.300, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Condition During our testing, we noted that the Organization did not provide adequate supporting documentation for ensuring proper suspension and debarment checks were performed. Cause The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the suspension and debarment requirements. Effect or Potential Effect Failure to timely verify that a recipient is not suspended or debarred could result in the Organization funding a person or entity that is barred from performing work for the U.S. government. Questioned Costs N/A Context For 5 suspension and debarment samples out of a total of 25 tested, management did not provide adequate supporting documentation for ensuring proper suspension and debarment checks were performed. None of the 5 samples were suspended or debarred. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that the Organization establish written suspension and debarment policies and procedures to ensure that the Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Views of Responsible Officials We will incorporate procedures in our grant compliance and administration policies and procedures that include appropriate searches for suspension and debarment prior to executing any financial transactions with covered persons.

Finding 2023-003 – Reporting - Significant Deficiency Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available Name of Pass-through Entity (if applicable): City of Scranton Criteria In accordance with §200.300, nonfederal entities are responsible for complying with all requirements of the Federal award. The Memorandum of Understanding between the City of Scranton and the Organization requires management to submit monthly financial and performance reports and a final project report. Condition During our testing, we noted that the Organization did not provide the required monthly reports to the City of Scranton. Cause The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the requirements regarding reporting. Effect or Potential Effect Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance with laws and regulations. Questioned Costs None Context For 2 report samples out of a total of 11 tested, management did not submit the required reports. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that the Organization establish policies, procedures, and controls to ensure that the required information is submitted on a timely basis. Views of Responsible Officials We will incorporate procedures in our grant compliance and administration policies and procedures that include a review and understanding of the reporting requirements.