United Way of the National Capital AreaNon-Profit

2023 – 001 Procurement – Suspension and Debarment Federal agency: Federal Emergency Management Agency Federal program title: Fund for Emergency Food and Shelter Program Federal Assistance Listing Number: 97.024 Award Period: June 1, 2022 – December 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. United Way of the National Capital Area should have internal controls designed to ensure compliance with those provisions and follow suspension and debarment procedures before entering into the transaction. Condition: During our testing, we noted United Way of the National Capital Area did not have documentation to support that internal controls were performed to ensure vendor and subrecipient were not suspended or debarred prior to entering into the first transaction. Additionally, the compliance check for one out of two vendors was not performed before the first transaction with the vendor. Questioned costs: None Context: During our testing, it was noted that for one of two vendors tested United Way of the National Capital Area did not have documentation to support that it had reviewed a subrecipient prior to entering into a contract with a subrecipient to ensure a subrecipient was not on the suspended or debarred organization list maintained by the General Services Administration. During our testing, it was also noted that for 1 of 2 items tested that United Way of the National Capital Area did not perform the vendor review procedures prior to the first transaction. We verified that these selected subrecipient and vendor were not suspended or debarred. Cause: United Way of the National Capital Area was unable to locate documentation to support the performance of procedures to ensure a subrecipient were not suspended or debarred. In addition, United Way of the National Capital Area did not perform the search for suspension and debarment prior to the first transaction. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend United Way of the National Capital Area design controls to ensure an adequate review process is in place to review potential vendor and subrecipient to determine they are not suspended or debarred and to ensure documentation to support this is maintained. We also recommend that the search for suspension and debarment is performed prior to entering the first transaction. Views of responsible officials: There is no disagreement with the audit finding.