Power Forward Communities, Inc.Non-Profit

Federal Agency: Environmental Protection Agency Federal Program Name: Greenhouse Gas Reduction Fund, National Clean Investment Fund Assistance Listing Number: 66.957 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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. The Corporation should have internal controls designed to ensure compliance with those provisions. In addition, 2 CFR 200.180.220 states, non-federal entities are prohibited from contracting with or making subawards under covered transactions to 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). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, 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 | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the procurement, suspension and debarment compliance requirement, we noted five debarment samples where the audit documentation for the review and approval over the controls was not properly maintained as related to 2 CFR Part 180.220. Questioned costs: Not determinable Context: During the audit, we noted the audit documentation surrounding the key controls over the search for debarment were not maintained in a central location. During our testing we selected 5 of the 9 contracts and subrecipients for testing. The audit documentation for the review and approval of the search for debarment was not maintained and could not be provided. Cause: PFC was relying on a professional consultant to assist with the development and monitoring of the controls related the Uniform Guidance. Effect: PFC entered in contracts with vendors during 2024 while a search for debarment occurred the documentation of the review and approval of the process were not maintained to comply with the requirements of the Uniform Guidance. Repeat Finding: No. Recommendation: We recommend that PFC ensure controls are in place so that the search for debarment are documented and saved in a secure location. Views of responsible officials: There is no disagreement with the audit finding.