Tucson Centers for Women & Children, Inc DBA Emerge Center Against Domestic Abuse

Finding Number: 2025‐001 Repeat Finding: No Program Name/Assistance Listing Title: Temporary Assistance for Needy Families (TANF) Assistance Listing Number: 93.558 Federal Agency: U.S. Department of Health and Human Services Federal Award Number: CTR066206, CTR064289 Pass‐Through Agency: Arizona Department of Economic Security, Arizona Foundation for Legal Services Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Eligibility Criteria Under eligibility guidelines for the Temporary Assistance for Needy Families (TANF) program, only  financially needy families that consist of a minor child living with a parent or a pregnant woman may receive  TANF  assistance.  In  accordance  with  2  CFR  200.303,  management  is  responsible  for  establishing and maintaining internal controls over federal programs, which includes developing a system to ensure documentation is maintained to support that program participants meet the TANF eligibility requirements. Condition The  documentation  Emerge  maintained  for  participants  reported  as  TANF  eligible  did  not  always  include information on whether the participant was pregnant or had children or dependents under the age of 19. Cause Emerge’s internal controls over documenting client information in the client management software were not adequate. Effect Two participants were incorrectly designated as TANF eligible. Context During our review of files for TANF eligible participants, we noted that for two of 21 participants reviewed,  Emerge  did  not  maintain  documentation  that  indicated  whether  the  participant  was  pregnant or had children or dependents under the age of 19. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management  should  ensure  that  intake  staff  not  only  inquire  whether  participants  meet  TANF  eligibility requirements, but also document such information prior to classifying the individual as TANF eligible. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Number: 404‐23, CT‐BH‐22‐208, 422939 Pass‐Through Agency: Arizona Coalition to End Sexual and Domestic Violence, Pima County, City of Tucson Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Additionally, non‐federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 §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 checking the System of Award Management (SAM) maintained by the General Services Administration (GSA), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition Adequate internal controls over procurement procedures to ensure compliance with Uniform Guidance regulations and guidelines were not in place. Verification of suspension and debarment was not performed for one vendor with whom Emerge Center Against Domestic Abuse (Emerge) spent at least $25,000 of federal grant monies. In addition, Emerge's procurement policy does not include the requirement for performing a suspension or debarment verification check on vendors procured with federal funds. Cause Emerge’s internal controls over procurement of goods and services were not adequate. Effect Emerge was not in compliance with the Uniform Guidance regulations and guidelines related to suspension and debarment. However, it was subsequently determined that the vendor utilized was not suspended or debarred. Context During our review of procurement, we noted that Emerge does not have a policy or procedure in place that requires a verification check of suspension and debarment for covered transactions. For one vendor with whom purchases exceeded $25,000, Emerge did not perform a verification check. Audit procedures determined the vendor was not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should develop and implement policies and procedures over procurement to ensure compliance with Uniform Guidance requirements under 2 CFR §180.300 and §200.318 through 326. Views of Responsible Officials See Corrective Action Plan.