Orleans Parish Sheriff's OfficeLocal Government

2024-002 Procurement and Suspension and Debarment Program: Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing Number 21.027, U.S. Department of Treasury passed through the City of New Orleans, Louisiana Compliance Requirement: Procurement and Suspension and Debarment Criteria: Non-federal entities are prohibited from contracting with parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) receiving a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). In addition, under 2 CFR 200.326, Contract Provisions, a non-federal entity’s contracts, must contain the applicable provisions described in Appendix II to Part 200, Title 2 - Contract Provisions for non-Federal Entity Contracts under Federal Awards. Condition: During our testing of compliance with the suspension and debarment regulations, the Office was unable to provide documentation of its determination during the procurement process that the 2 of the 3 vendors selected for testing were not suspended or debarred. Based on our review of SAM.gov, these vendors were not suspended or debarred. In addition, for 2 of the 3 contracts selected for testing, the required provisions described in Appendix II to Part 200 - Contract Provisions for non-Federal Entity Contracts under Federal Awards were not included. The universe (population) from which the vendors and contracts were selected were all contracts over $25,000 with expenditures incurred during 2024 consisting of 4 contracts. Questioned Costs: None Cause: Management did not maintain documentation of the Office’s determination of whether vendors were suspended or debarred for all covered transactions. Effect: Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the Office may enter into contracts with suspended or debarred parties. Recommendation: We recommend that the Office review all contracts to ensure the appropriate language exits regarding suspension and debarment regulations, and the Office should consider an annual review of SAM.gov for all vendors that are paid from federal awards. In addition, the Office should implement procedures to ensure that contracts paid with federal funds have the provision as required by Appendix II to Part 200, Title 2 - Contract Provisions for non-Federal Entity Contracts under Federal Awards. Views of responsible officials and planned corrective action: OPSO acknowledges the finding and appreciates the importance of maintaining documented verification of vendor eligibility and ensuring all federally required provisions are present in contracts funded by federal awards. We would like to clarify that the two vendors in question were not suspended or debarred according to SAM.gov records at the time of the audit. However, OPSO did not retain adequate documentation of the verification performed at the time of procurement, nor did we fully integrate all Appendix II provisions in the contract files reviewed. This deficiency did not result from intentional noncompliance but from gaps in procedural oversight and documentation retention stemming from historical procurement practices and limited internal controls over contract file completeness. Corrective Action Plan To address the finding and ensure full future compliance with 2 CFR § 180.300, § 200.326, and related guidance, OPSO has implemented the following corrective actions: 1. Contract File Documentation Protocol - Effective July 1, 2025, all procurement files for federal contracts exceeding $25,000 must include: • A printed or digitally archived screenshot of the SAM.gov record showing the vendor’s exclusion status. • A signed vendor eligibility certification form confirming the entity is not suspended, debarred, or otherwise excluded. • A signed checklist confirming inclusion of required Appendix II contract provisions. All contract files will be centrally stored and monitored by OPSO’s Procurement Division. 2. Updated Procurement Templates - OPSO has updated all procurement and contracting templates to: • Include the full list of required provisions from Appendix II to Part 200. • Add a standard Suspension and Debarment certification clause. • Automatically require review of the SAM.gov Exclusions List prior to final contract execution. 3. Staff Training and Compliance Oversight - All staff involved in procurement and grant-funded contracting were trained on federal procurement standards and suspension and debarment requirements on December 31, 2025. Refresher trainings will occur semi-annually and be required for new staff during onboarding. A pre-award compliance checklist has been instituted to ensure proper documentation and verification steps are followed and archived. 4. Post-Award Compliance Reviews - Beginning Q4 of Fiscal Year 2025, OPSO’s Internal Audit and Compliance Division will conduct quarterly reviews of all federal contract files to ensure: • Proper documentation of vendor eligibility. • Compliance with contract content requirements under 2 CFR Part 200. Findings will be reported directly to the Chief Financial Officer and Sheriff for corrective follow-up if deficiencies are found. Conclusion: OPSO remains fully committed to upholding all federal procurement and grant compliance standards. While this finding did not result in questioned costs, we recognize the risk it poses and have taken decisive action to enhance internal controls, training, and documentation standards. We appreciate the audit team’s diligence and remain available to provide any further documentation or clarification needed.

2022-001 Timely Submission of Audit Reports Criteria: In accordance with the Louisiana Revised Statute (R.S.) 24:513 and 24:514, audit reports are due to the Louisiana Legislative Auditor (LLA) no later than six months after the local auditee’s fiscal year end. In accordance with the Uniform Guidance, the Office is required to submit the annual audit reporting package and Data Collection Form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditors’ reports or nine months after the end of the audit period. Condition: The Office did not meet the June 30, 2023 deadline for reporting to the LLA and the September 30, 2023 deadline for reporting to the Federal Audit Clearinghouse. Context/Cause: Due to staffing shortages and turnover at key management positions, the Office’s 2021 audit was completed in June 2023, and as a result, the 2022 audit was delayed as the Office needed additional time to prepare for the audit. Effect: The Office is not compliant the Louisiana Legislative Auditor and Uniform Guidance reporting requirements. Indication of a repeat finding: This is a repeat finding related to the Louisiana Legislative Auditor reporting requirement. The Office was not required to have a Uniform Guidance audit for 2021. Recommendations: The Office should implement procedures to ensure that future audits are submitted by the required deadlines. The Office should consider consultants to assist with preparation for the audit. Views of responsible officials and planned corrective action: The Orleans Parish Sheriff's Office has a late filing audit finding in connection with our 2022 audit. This audit was due to be filed June 30, 2023. Due to a staff shortage, the 2021 financial audit was not filed until June 2023. This delayed the commencement of the 2022 audit until after the filing deadline. Prior to this time, the Office's internal auditor, who was integral in compiling the audit, had not been replaced since retiring and the Chief Financial Officer was dismissed from his position and not replaced. This left the Accounting Department with two full time accountant and the Comptroller who absorbed the Internal Auditor's duties as well as the Chief Financial Officer's duties. This abrupt staffing issue left the Office significantly delayed in compiling the necessary information for the 2022 audit. To try and expediate the 2022 audit, the Office has engaged EisnerAmper to prepare the financial statements as opposed to the Office preparing the financial statements. We anticipate this will ensure that the 2023 statements are completed expeditiously in order for the department to ensure that the 2023 audit will filed by the June 30, 2024 deadline.

2022-002 Compliance with FEMA Reporting Requirements Federal Program: Public Assistance - Disaster Grants, Assistance Listing Number 97.036 Criteria: Reporting requirements of the Public Assistance - Disaster Grants mandate that quarterly performance reports be submitted to the grantor within 30 days after the end of each quarter. Condition/Context: The Office submitted the quarterly report for the quarter ended March 31, 2022 after the 30-day deadline. Reports for the remaining quarters were not submitted. Statistically Valid Sample: N/A Cause: Reports were not submitted timely for the first quarter of 2022 and not submitted after this quarter due to turnover in staff responsible for grant reporting. Questioned Costs: None. Recommendation: We recommend that the Office implement procedures to ensure that all reports are properly submitted by the required deadlines. Views of responsible officials and planned corrective action: The Orleans Parish Sheriff's Office is delinquent in filing quarterly performance reports. The task of filing the reports fell on the Internal Auditor/FEMA Auditor. This employee retired May 2021 and has not been replaced as of this filing. We have requested that our Attorneys who taken the lead with communications and submissions to FEMA and GOHSEP file all of the delinquent reports and continue to file them until these critical positions are filled.

Criteria: In accordance the Uniform Guidance, the Office is required to submit the annual audit reporting package and Data Collection Form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditors? reports or nine months after the end of the audit period. In March 2021, the Office of Management and Budget issued Memorandum M-21-20, which states that awarding agencies should allow recipients and subrecipients with fiscal year ends through June 30,2021, that have not yet filed their single audits with the Federal Audit Clearinghouse to delay the completion and submission of the single audit reporting package to six months beyond the normal due date. As the Office?s normal due date was September 30, 2021, the allowed extension was through March 31, 2022.Condition: The Office did not meet the extended March 31, 2022 deadline for reporting to the Federal Audit Clearinghouse. Context/Cause: When the Covid-19 outbreak began in 2020, the Office put all nonessential employees on furlough, including most administrative, accounting, and financial personnel. Accounting and financial personnel were gradually brought back, however some remained on a part time basis throughout most of 2020. In addition, the Office also lost some key middle management personnel who were responsible for certain financial information needed for the audit. The lack of staff significantly impacted the completion of schedules provided to the auditors. There were also delays in receiving certain information from third parties that were also impacted by Covid-19. Effect: The Office is non-compliant the Uniform Guidance requirement to submit the audit to the Federal Audit Clearinghouse by March 31, 2022. Questioned Costs: For the purposes of this finding, there were no questioned costs. Indication of a repeat finding: This is a repeat finding from the previous audit, 2019-001. Recommendations: The Office should implement procedures to ensure that the 2022 audit is submitted by the deadline. Views of responsible officials and planned corrective actions: Due to a material staffing furlough and administrative restrictions by the Office due to the COVID pandemic, the 2019 financial audit was not filed until July 2021. This delayed the commencement of the 2020 audit until after the filing deadline. During this period, the Office's internal auditor, who was integral in compiling the audit, retired. This resignation and departure left the Accounting Department with one full-time accountant and the Comptroller who absorbed the Internal Auditor's duties. This unexpected staffing issue left the Office significantly delayed in compiling the necessary information for the 2020 audit. As of October 2022, two full time Accountants have been added to the Accounting Staff and the Office has engaged the external auditors to prepare the Office?s future financial statements as opposed to the Office preparing the financial statements.

2019-001 Timely Submission of Audit to the Federal Audit Clearinghouse Criteria: In accordance the Uniform Guidance, the Office is required to submit the annual audit reporting package and Data Collection Form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditors? reports or nine months after the end of the audit period. In March 2021, the Office of Management and Budget issued Memorandum M-21-20, which states that awarding agencies should allow recipients and subrecipients with fiscal year ends through June 30, 2021, that have not yet filed their single audits with the Federal Audit Clearinghouse to delay the completion and submission of the single audit reporting package to six months beyond the normal due date. As the Office?s normal due date was September 30, 2020, the allowed extension was through March 31, 2021.Condition: The Office did not meet the extended March 31, 2021 deadline for reporting to the Federal Audit Clearinghouse. Context/Cause: When the Covid-19 outbreak began in 2020, the Office put all nonessential employees on furlough, including most administrative, accounting, and financial personnel. Accounting and financial personnel were gradually brought back, however some remained on a part time basis throughout most of 2020. In addition, the Office also lost some key middle management personnel who were responsible for certain financial information needed for the audit. The lack of staff significantly impacted the completion of schedules provided to the auditors. There were also delays in receiving certain information from third parties that were also impacted by Covid-19. Effect: The Office is non-compliant the Uniform Guidance requirement to submit the audit to the Federal Audit Clearinghouse by March 31, 2021. Recommendations: The Office should implement procedures to ensure that the 2020 audit is submitted by the deadline. Views of responsible officials and planned corrective actions: The Orleans Parish Sheriff?s Office accounting department staff was furloughed due to Covid-19 for the months of March 2020 ? August 2020. This staffing shortage created a delay in the Office?s 2019 audit. As of January 2021, the accounting department has resumed all functions and staff has resumed working full schedules. The Sheriff?s Office anticipates filing the audit by the September 30th deadline.