Emmaus Homes Inc.Non-Profit

Finding 2024-001 - Significant Deficiency: Procurement and Suspension and Debarment – Compliance and Control Finding ALN 21.027 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: Developmental Disabilities Resource Board of St. Charles County Fiscal Year End: For the year ended June 30, 2024 Criteria Or Specific Requirement: The Uniform Guidance requires the Organization to adhere to federal procurement requirements when expending federal funds. The Organization also must adhere to federal requirements to ensure that its contractors have not been suspended or debarred from receiving federal funds. Condition: The Organization procured constructions services with one vendor in an amount in excess of the $250,000 simplified acquisition threshold. Required sealed bid procurement methods were not followed for this vendor. Additionally, the Organization did not maintain documentation of their review that this contractor had not been suspended or debarred from receiving federal funds by either including appropriate language to this effect within the contract or maintaining documentation that the contractor was not included within the suspension and debarment listing within the EPLS database. Cause: The Organization did not have a documented procurement policy in place to ensure that procurement and suspension and debarment procedures were followed and/or documented. Effect: The Organization could contract with a contractor who is either not the most qualified and/or lowest cost provider, or who is suspended or debarred. Context: The Organization procured constructions services with one vendor in an amount in excess of the $250,000 simplified acquisition threshold. Bids were received from four vendors and the lowest cost provider was selected; however, sealed bid procurement procedures, including ensuring free and open competition, were not followed. In addition, the Organization did not maintain documentation supporting their verification that the contract was not suspended or debarred at the time the contract was executed. Review confirmed the contractor is not suspended or debarred. Questioned Costs: None noted. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document and follow a procurement policy in alignment with the Uniform Guidance requirements. Views Of Responsible Officials: Procurement procedures were followed in accordance with the requirements specified within the agreement with the Developmental Disabilities Resource Board of St. Charles County, including the receipt of multiple bids. The lowest bid was selected. For future procurement transactions, the Organization is aware of the additional Uniform Guidance requirements and will ensure compliance, if necessary.