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U.S. Agency for International Development 1300 Pennsylvania Avenue, NW Washington, DC 20523 www.usaid.gov
Issuance Date: December 21, 2020 Questions Due by: December 26, 2020 Closing Date: January 5, 2021 Closing Time: 4:30 PM, Kabul Time
SUBJ: USAID Request for Quotations (RFQ) No. 72030621Q00001, under the GSA Schedule, FINANCIAL AND BUSINESS SOLUTIONS (FABS)/ Special Item Number (SIN) 520- 7 entitled Financial & Performance Audits.
TO ALL INTERESTED PARTIES:
The United States Government, represented by the U.S. Agency for International Development (USAID), is soliciting quotations from qualified GSA contractors interested in providing the services detailed in the attached Statement of Work (SOW). The purpose of this Order is to acquire audit and financial services for the USAID/Afghanistan Office of Financial Management
(OFM).
Responses will only be considered from Offerors who hold a current Professional Services Schedule (PSS) GSA Multiple Award Schedule (MAS) Contract, under the Financial and Business Solutions (FABS), Special Item Number (SIN) 520-7 entitled Financial & Performance Audits. The North American Industry Classification System (NAICS) code for this RFQ is 541211 – Offices of Certified Public Accountants.
Award of an Order under the GSA Federal Supply Schedule will follow the GSA competitive ordering procedures in order to determine the best value. This order is anticipated to be awarded based on initial offers. The Contractor will propose a firm fixed price with reimbursable travel and per diem.
Proposals will be evaluated on the basis of the criteria described in the Section M. Award will be made to the offeror whose proposal offers the best value to the Government considering both technical and price factors. This order is for a twelve (12) month base period.
Please provide your proposal electronically by the closing date above. Please scan those pages requiring signatures. All questions should be sent by e-mail directed to the contact person listed below in writing no later than the due date above. All responses to questions which clarify or provide additional information will be provided to all contractors.
Any questions as well as submission of proposals in response to this RFQ must be directed to:
Contract Specialist Mr. Khan Mohammad Zamani at kmzamani@usaid.gov with a copy to Sr.
Acquisition & Assistance Specialist Mr. Henok Amenu Oljira at hamenu@usaid.gov and Contracting Officer Mr. Diego Marquez at dmarquez@usaid.gov.
72030621Q00001
This RFQ in no way obligates USAID to award an order, nor does it commit USAID to pay any costs incurred in the preparation and submission of the proposal.
Sincerely, Diego Marquez Contracting Officer Office of Acquisition and Assistance USAID/Afghanistan
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SECTION B SERVICES AND PRICES/COSTS
B.1 AUTHORITY
This Order is entered into pursuant to the Federal Acquisition Regulation (FAR) Part 8.4
B.2 PURPOSE
The purpose of this Task Order is to provide financial audit services as described in detail in Section C for the financial audit of costs incurred for Afghanistan including a review of compliance with vetting procedures for USAID/Afghanistan. The estimated amount to be audited is specified for each Group under Section C.
B.3 CONTRACT TYPE
This is a firm fixed price (FFP) type task order with reimbursable travel and per diem.
B.4 FIRM FIXED PRICE
This is a Firm Fixed-Price order for a twelve (12) month base period. The Contractor must perform services for the Firm Fixed Price proposed, regardless of the amount of labor days required to complete the scope of work and deliverables.
FFP for period of performance (twelve (12) months base period) $(TBD) Reimbursable Travel $90,000.00 Total Ceiling Cost $(TBD)*
*The contractor is not entitled to the total ceiling amount mentioned above. While the FFP amount will be paid to the contractor in full amount the Reimbursement Travel cost will be paid on actual cost bases.
The contractor will not be paid above the Total Ceiling Cost under any circumstance.
B.5 OBLIGATED AMOUNT
Within the firm fixed price specified in paragraph B.3.above, the amount currently obligated and available for payment to the Contractor for performance hereunder is $(TBD). The amount obligated for travel is $(TBD). The Total Obligated Amount is $(TBD). The Contractor shall not exceed the aforesaid obligated amounts.
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B.6 PAYMENT SCHEDULE
Payment will be made in accordance with FAR 52.232-32 Performance-Based Payment and will be made as the work proceeds based on estimates of work accomplished as set forth in the table below and in accordance with standards outlined in Section E – Review Checklist.
Deliverable Description Payment Amount
#1 Approved Audit Work Plan and Milestone Plan
20% $[TBD]
#2 Approved draft final (# of reports TBD) Audit Reports
30% $[TBD]
#3 Approved Final (# of reports TBD) Audit Reports
30% $[TBD]
#4 Final (# of reports TBD) Audit Report Accepted by OIG
20% $[TBD]
Total Amount 100% $[TBD]
B.7 OTHER DIRECT COSTS –TRAVEL
a) Local travel, commuting costs or the relocation of Contractor personnel from other geographic areas for the purpose of staffing a project are not subject to Government reimbursement. The Government will not pay charges for travel to and from the Contractor's home to a Government office or offices or to/from one company or subcontractor's building to another. Travel for technical personnel on approved STTA and LTTA to missions is reimbursable.
b) All international travel shall be in compliance with the provisions of the Federal Travel
Regulations (FTR) 301.10.121, Federal Acquisition Regulation (FAR) Subpart 31.205-46 and USAID Travel Policy. The Federal Travel Regulations and current per diem rates can be accessed at: http://www.gsa.gov/ftr.
c) No profit or fee will be applied to Travel, in accordance with FAR 16.601.
[END OF SECTION B]
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SECTION C - DESCRIPTION/SPECIFICATIONS/STATEMENT OF WORK
C.1 BACKGROUND
The U. S. Agency for International Development (USAID) Mission in Afghanistan is seeking a highly qualified audit firm to conduct financial and closeout audit services, including a review of compliance with vetting procedures, on various projects implemented by three contractors. The audit shall ensure that USAID funds are properly accounted for; used for their intended purposes, and in compliance with applicable regulations, policies and procedures. The contractors and awards covered under this statement of work are:
Group A:
1. ABT Associates Inc., under award number 306-AID-OAA-A-15-00067, SHOPS Plus, for the period from 1/1/2019 to 9/30/2020
2. ARD, under award number 306-AID-306-C-15-00005, Initiative to Strengthen Local Administration (ISLA), for the period from 2/1/2020 to 3/31/2021
3. AUAF, under award number 306-A-13-00004, Support to the American University of Afghanistan (AUAF), for the period from 6/1/2020 to 10/31/2020
4. Blumont Global Development Inc., under award number 306-72030618CA00005, Conflict Mitigation Assistance for Civilians (COMAC), for the period from 6/1/2020 to 10/31/2020
5. Care International, under award number 306-72030618CA00007, Livelihood Advancement for Marginalized Population (LAMP), for the period from 8/1/2018 to 12/30/2020
Awards Information for Group A:
Auditee ABT
ASSOCIATES
INC.
ARD -
ASSOCIATES IN
RURAL
DEVELOPMENT
AUAF -
American University of Afghanistan
Blumont Global Development, Inc.
CARE
International
Award No. 306-AID-OAA- A-15-00067
306-AID-306-C-15-
00005
306-A-13-00004 306-
72030618CA00005
306-
72030618CA00007
Project Name
SHOPS Plus Initiative to Strengthen Local Administration
(ISLA)
Support to the American University of Afghanistan
Conflict Mitigation Assistance for Civilians (COMAC)
Livelihood Advancement for Marginalized Population
(LAMP)
Audit Type
Closeout Closeout Closeout Financial Financial
Project Start Date
10/11/2015 02/01/2015 08/01/2013 03/12/2018 08/01/2018
Project End Date
09/30/2020 03/31/2021 10/31/2020 03/11/2023 07/31/2022
Period to be Audited
1/1/2019 to 9/30/2020
2/1/2020 to 3/31/2021
6/1/2020 to 10/31/2020
6/1/2020 to 10/31/2020
8/1/2018 to 12/30/2020
Total Estimated
12,500,000 52,500,000 90,681,844 39,999,873 9,491,153
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Costs
(TEC)
Amount to be Audited
6,356,868 4,926,612 5,920,589 2,802,379 2,661,769
Record Location
Kabul, Afghanistan
* The total estimated amounts to be audited are estimates that were calculated based on available information at the time of this solicitation. The actual amount may not be the exact total to be audited at the time of contract execution since all funds incurred in Afghanistan during the period must be audited by the successful contractor.
Group B:
1. Checchi & Company Consulting Inc., under award number 306-AID-306-TO-16-00007, Assistance for the Development of Afghan Legal Access and Transparency (ADALAT), for the period from 7/1/2020 to 4/17/2021
2. Chemonics, under award number, 306-AID-OAA-TO-15-00007, Global Health Supply Chain Management (GHSCM-PSM), for the period from 1/1/2018 to 4/19/2020
3. DABS, under award numbers:
- 306-IL-13-22-7, Power Transmission Expansion and Connectivity (PTEC), for the period from 1/1/2019 to 12/31/2020 and
- 306-IL-15-56-09, Claims Related to the Installation of Turbine Generator Unit 2 at
Kajaki Dam Hydropower Plant, for the period from 04/01/2013 to 12/31/2016
4. DAI, under award numbers:
- 306-AID-306-C-14-00016, Strong Hubs for Afghan Hope and Resilience (SHAHAR), for the period from 12/1/2019 to 3/31/2021 and
- 306-AID-OAA-C-17-00090, INVEST, for the period from 12/1/2018 to 09/27/2020
Awards Information for Group B:
Auditee Checchi and Company Consulting, Inc
(CCCI)
Chemonics International Inc.
DABS DABS DAI-
Development Alternatives Inc.
DAI-
Development Alternatives Inc.
Award No. 306-AID-306-
TO-16-00007
306-AID-
OAA-TO-15-
00007
306-IL-13-22-
306-IL-15-56-09 306-AID-306-
C-14-00016
306-AID-OAA-
C-17-00090
Project Name
Assistance for the Development of Afghan Legal Access and Transparency
(ADALAT)
Global Health Supply Chain Management
(GHSCM-
PSM)
Power Transmission Expansion and Connectivity
(PTEC)
Claims Related to the Installation of Turbine Generator Unit 2 at Kajaki Dam Hydropower Plant
Strong Hubs for Afghan Hope and Resilience
(SHAHAR)
INVEST
Audit Type
Closeout Closeout Financial Closeout Closeout Closeout
Project Start Date
04/18/2016 04/20/2015 01/01/2013 04/01/2013 11/30/2014 09/28/2017
Project End Date
04/17/2021 04/19/2020 12/31/2023 12/31/2016 03/31/2021 09/27/2020
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Period to be Audited
7/1/2020 to 4/17/2021
1/1/2018 to 4/19/2020
1/1/2019 to 12/31/2020
04/01/2013 to 12/31/2016
12/1/2019 to 3/31/2021
12/1/2018 to 09/27/2020
Total Estimated Costs
(TEC)
68,163,468 176,568 316,713,724 5,000,000 73,499,999 15,000,000
Amount to be Audited
3,691,825 - 19,406,272 - 10,036,679 6,822,186
Record Location audited at the time of contract execution since all funds incurred in Afghanistan during the period must be audited by the successful contractor.
Group C:
1. FHI 360, under award number 306-AID-OAA-C-15-00001, Global Health Supply chain Quality Assurance (GHSC-QA), for the period from 10/1/2017 to 12/31/2019
2. ICF MACRO Inc., under award numbers:
- 306-7200AA18C00083, Afghanistan Demographic and Health Survey (ADHS)
Follow-On, for the period from 10/9/2018 to 12/31/2020 and
- 306-AID-OAA-C-13-00095, Demographic and Health Surveys, for the period from
1/1/2018 to 9/8/2018
3. International Medical Corps, under award number 306-720FDA18CA00003, Provision of Humanitarian WASH Assistance to Afghan Returnees, IDPs and Vulnerable Local Communities in Nangarhar and Kunar Province, for the period from 12/08/2017 to 09/07/2019
4. JHPIEGO, under award number 306-AID-306-A-15-00002, HEMAYAT, for the period from 7/1/2018 to 12/06/2020
Awards Information for Group C:
Auditee FHI 360 ICF MACRO INC ICF MACRO
INC
International Medical Corps
JHPIEGO
Corporation
Award No. 306-AID-OAA- C-15-00001
306-
7200AA18C00083
306-AID-OAA-
C-13-00095
306-720FDA18CA00003 306-AID-306-A-
15-00002
Project Name
Global Health Supply chain Quality Assurance
(GHSC-QA)
Afghanistan Demographic and Health Survey (ADHS) Follow-On
Demographic and Health Surveys
Provision of Humanitarian WASH Assistance to Afghan Returnees, IDPs and Vulnerable Local Communities in Nangarhar and Kunar Province
HEMAYAT
Audit Type
Closeout Financial Closeout Closeout Closeout
Project Start Date
01/02/2015 10/09/2018 09/09/2013 12/08/2017 01/07/2015
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Project
12/31/2019 09/09/2023 09/08/2018 09/07/2019 12/06/2020
Period to be Audited
10/1/2017 to 12/31/2019
10/9/2018 to 12/31/2020
1/1/2018 to 9/8/2018
12/08/2017 to 09/07/2019
7/1/2018 to 12/06/2020
Total Estimated Costs
(TEC)
1,500,000 10,500,000 6,699,863 2,000,000 66,292,151
Amount to be Audited
(151,198) 2,000,000 - 1,851,318 22,425,907
Record Location
Durham, NC 2 & Connecticut Avenue, NW
Washington, DC audited at the time of contract execution since all funds incurred in Afghanistan during the period must be audited by the successful contractor.
Group D:
1. John Snow Incorporated, under award number 306-AID-OAA-TO-10-00066, Contraceptive Procurement (CCP), for the period from 9/30/2015 to 12/31/2018
2. KNCV, under award number 306-AID-OAA-A-14-00029, Challenge Tuberculosis, for the period from 10/1/2018 to 1/31/2020
3. Red Orange North America Inc., under award number 306-72030619P00024, Spare parts for Tarakhil Power Plant, for the period from 08/14/2019 to 10/30/2020
4. TAF, under award number 306-AID-306-C-17-00014, Financial and Business Management Activity, for the period from 3/5/2020 to 10/31/2020
5. TEXAS A&M AGRILIFE RESEARCH, under award number 306-72030618CA00009, Promote Scholarship Endowment Activity, for the period from 9/27/2018 to 12/31/2020
Awards Information for Group D:
Auditee JOHN SNOW, INCORPORATED
KNCV Red Orange North America Inc.
TAF-The Asia Foundation
TEXAS A&M
AGRILIFE
RESEARCH
Award No.
306-AID-OAA-TO-
10-00066
306-AID-OAA-
A-14-00029
306- 72030619P00024
306-AID-306-C-
17-00014
306-
72030618CA00009
Project Name
Contraceptive Procurement (CCP)
Challenge Tuberculosis
Spare parts for Tarakhil Power Plant
Financial and Business Management Activity
Promote Scholarship Endowment Activity
Audit Type
Closeout Closeout Closeout Closeout Financial
Project Start Date
11/01/2011 01/01/2015 08/14/2019 07/05/2017 09/27/2018
Project
12/31/2018 01/31/2020 10/30/2020 10/31/2020 09/26/2023
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Period to be Audited
9/30/2015 to 12/31/2018
10/1/2018 to 1/31/2020
08/14/2019 to 10/30/2020
3/5/2020 to 10/31/2020
9/27/2018 to 12/31/2020
Total Estimated Costs
(TEC)
13,535,571 15,700,000 2,136,850 4,384,058 50,000,000
Amount to be Audited
1,315,556 4,200,000 2,099,597 515,469 50,000,000
Record Location audited at the time of contract execution since all funds incurred in Afghanistan during the period must be audited by the successful contractor.
C.2 AUDIT TITLE
● Financial or Closeout audit of Costs Incurred in Afghanistan of the USAID Resources Managed by the implanting partners under the respective awards specified in tables above under section C1.
C.3 AUDIT OBJECTIVES
The financial audit objectives must include the following:
A. Audit of USAID Funds
Auditors must design steps and procedures in accordance with GAGAS. A financial audit of the funds provided by USAID must be performed in accordance with Government Auditing Standards, or other approved standards where applicable, and accordingly includes such tests of the accounting records as deemed necessary under the circumstances. The specific objectives of the audit of the USAID funds are to:
● Express an opinion on whether the fund accountability statement for the USAID-funded programs presents fairly, in all material respects, revenues received, costs incurred, and commodities and technical assistance directly procured by USAID for the period audited in conformity with the terms of the agreements and generally accepted accounting principles or other comprehensive basis of accounting (including the cash receipts and disbursements basis and modifications of the cash basis, if appropriate).
● Evaluate and obtain a sufficient understanding of the contractor's internal controls related to the USAID-funded programs, assess control risk, and identify reportable conditions, 10 | P a g e including material internal control weaknesses. This evaluation must include the internal controls related to required cost-sharing contributions.
● Perform tests to determine whether the contractor complied, in all material respects, with agreement terms (including cost-sharing/matching contributions, if applicable) and applicable laws and regulations related to USAID-funded programs. All material instances of noncompliance and all illegal acts that have occurred or are likely to have occurred must be identified. Such tests must include the compliance requirements related to any required cost-sharing contributions.
In addition, if applicable:
● Review cost-sharing/matching contributions to determine whether cost-sharing/counterpart contributions were provided and accounted for by the implementing partner in accordance with the terms of the agreements. The auditors will review the cost-sharing/counterpart table to determine if the computation is fairly presented in accordance with the basis of accounting used by the implementing partner to prepare the schedule. The auditors should question all cost-sharing/counterpart contributions that are either ineligible or unsupported costs.
● For a non U.S. Organization, perform an audit of the indirect cost rate(s) if the contractor has been authorized to charge indirect costs to USAID using provisional rates. If so, the fund accountability statement should be reconciled to the USAID funds included in the general purpose income statement by a note to the fund accountability statement. If the contractor does not have a USAID authorized indirect cost rate, this fact must be disclosed in the report.
● For a non U.S. Organization, if the recipient has been authorized to charge provisional indirect cost rate, then perform a financial audit of the recipient’s organization-wide general-purpose financial statements.
● The audit of the general purpose financial statements must be performed in accordance with GAGAS. The objective of this audit is to express an opinion on whether the general purpose financial statements present fairly, in all material respects, the results of its operations for the year then ended, in conformity with generally accepted accounting principles.
● Determine if the contractor has taken adequate corrective action on prior audit report recommendations.
Auditors must design steps and procedures in accordance with Government Auditing Standards, Chapter 4, to provide reasonable assurance of detecting situations or transactions in which fraud or illegal acts have occurred or are likely to have occurred. If such evidence exists, the auditors must immediately contact the appropriate USAID Mission and the Office of Inspector General’s
11 | P a g e cognizant regional office and must exercise due professional judgment in pursuing indications of possible fraud and illegal acts so as not to interfere with potential future investigations or legal proceedings.
B. Review of the Compliance with Vetting and Sub-Awards and Procurement
Auditor is required to perform a review of Auditee’s compliance with vetting procedures. The Auditor must review the following documents before commencing this review:
1. The United States prohibition against support for terrorism, as stipulated in Executive Order 13224 and as required in USAID/Afghanistan’s Mission Order (MO) 201.03 entitled “Terrorist Financing Risk Assessment” effective October, 2009; as supplemented by MO
201.06 (National Security Screening (Non-US Party Vetting), dated June 7, 2015; and award provision no. A.16.12, Vetting;
2. IP Letter issued by the Office of Acquisition and Assistance (OAA) #OAA-IP-2013-010 dated 11/25/2013, entitled “Consolidation of Vetting Requests per MO 201.05” and IPs Letter #OAA-IP-2013-007 dated 7/23/2013, entitled “Updated MO 201.05 – National Security Screening (Non-US Party Vetting)”; Anti-Terrorism Certification (ATC) - In order to ensure compliance with E.O. 13221 and related requirements, all contractors are expected to conduct their own review of Non-US Parties competing for Sub-Awards. The audit must conduct focused review of Partner’s files including sub-award documentation to verify that it complies with all vetting sub-awards compliance related procedures including Vetting Special Provisions, and Instructions to contractors issued by the Office of Acquisition and Assistance (OAA) and Anti-Terrorism clauses (ATC). The auditor will perform the following categorical reviews for each sub award:
a. Review and determine if awardee has complied with the vetting requirements outlined in Mission Order No. 201.03 (and its supplement(s) entitled, ‘National Security Screening (Non-US Party Vetting)’. Review and determine if internal procedures were established by the awardee to ensure compliance with Mission Order No. 201.03 as supplemented.
b. Check if contractor has implemented and followed procedures designed to ensure that funds are not being diverted from their development purpose outlined in the contract and are not vulnerable to corruption, extortion or otherwise benefiting malign groups.
c. For sub-awards over $25,000 or that cumulatively total more than $25,000 over any 12 month period: Review IP’s procurement files and obtain a complete list of contracts, subcontracts, grants, sub-grants, vendors. Check that the full name of the subcontractor is accurately written in English if the name has been translated.
Compare the full name of the subcontractor as it appears in the sub-award against any approval documents such as vetting. Check that sub-contractors are properly licensed with GIRoA. Send the list of the sub-awardees to the USAID’s Vetting Unit to cross-check against its list of vetting approvals.
d. Check the instrument of all sub-awards with a value exceeding $25,000: What is
12 | P a g e the sub-award type? (Contract, Grant, Memorandum of Understanding (MOU) or other). Were proper procedures/provisions/rules followed in contract with the type of instrument used?
e. Check the start date of all sub-awards with a value exceeding $25,000: When was the sub-award signed? Was vetting approval received prior to award? Was consent to sub-award approval, if required, received prior to award?
f. Check the end date of all sub-awards with a value exceeding $25,000: When did the sub-award end? Were there any amendments? Have these been reported if required?
g. Check that the prime contractor electronically transfers all project funds to sub-contractors. If they do not, does the financial infrastructure exist for them to do so?
h. Check that sub-contractors are limited to two tiers below the prime contractor in accordance with any applicable requirements.
i. Check that all required information has been properly input into the FFATA Sub award Reporting System (FSRS) if sub-award is over $25,000.
j. Ascertain whether the prime contractor ensured that periodic audits of its sub-contractors were performed to ensure accountability for USAID funds.
k. Review all required certifications, including anti-terrorism mandatory provisions, were obtained and included in the sub-award document.
l. Check that contractor has a system in place to provide training to sub-contractors on financial controls, reporting requirements and business ethics and monitors sub-contractors on their performance in these areas.
m. Obtain, review, and provide a recommendation of the adequacy, efficiency, and internal controls of the IP’s procedures and processes with regard to the implementation of the MO 201.06.
n. Review and determine if IP’s and sub-award/subcontract key individuals requiring vetting, as defined in MO 201.06, were appropriately submitted for vetting in advance of contract award or upon reaching $25,000 in a one year period.
o. Verify compliance with Appendix A section 6 of MO 201.06:
i. Determine if new vetting was conducted for awards that exceed one year or were modified to increase in duration to exceed one year
ii. Determine if new vetting was conducted in instances where there were changes in the awardee’s key individuals;
iii. Determine if new vetting was conducted for awards that had substantial changes (i.e., location, award amount, time frame);
p. Check that a written code of conduct has been created which is sufficient to ensure due diligence is followed to prevent and detect criminal conduct, conflict of interest and to otherwise promote an organizational culture that promotes ethical conduct and a commitment to compliance with the law.
q. For any instance of any non-compliance to USAID’s vetting policies and procedures, the Contractor must as applicable report the following:
i. Name of contractor, type of award, type of service received, amount of the award;
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ii. The circumstances behind the non-compliance;
iii. Internal control deficiency or non-compliance with internal control policies and procedures;
iv. Provide recommendations to address the internal control deficiency or non-compliance with internal control policies and procedures.
C.4 AUDIT SCOPE
The financial audit must include a specific audit of all the recipient’s USAID-funded programs.
The objective of this engagement is to conduct a financial audit based on the fiscal year end or closeout audit of costs incurred in Afghanistan including a review of the compliance with vetting procedures and National Technical Assistance guidelines by the implementing partner(s) listed under section C.1 in accordance with the specifications outlined in the statement of work and in accordance with:
● USAID Financial Audit Guide (hereinafter referred to as the Guide);
● U.S. Generally Accepted Government Auditing Standards (GAGAS or the "Yellow
Book"); hereinafter referred to as GAGAS, issued by the Comptroller General of the United States General Accountability Office; and , as applicable;
● International Standards on Auditing issued by the International Auditing and Assurance Standards Board (IAASB) of the International Federation of Accountants (IFAC), in conjunction with GAGAS; and
● The International Standards of Supreme Audit Institutions (ISSAIs) issued by the International Organization of Supreme Audit Institutions (INTOSAI) for public-sector audits, in conjunction with GAGAS.
The auditor must use the following steps as the basis for preparing audit programs. They are not all-inclusive or restrictive in nature and do not relieve the auditor from exercising due professional care and judgment. The steps must be modified to fit local conditions and specific program design, implementation procedures, and agreement provisions which may vary from program to program.
Any limitations in the scope of work must be communicated as soon as possible to the USAID cognizant COR and Contracting Officer.
A. Pre-Audit Document Review
Following is a list of documents applicable to different USAID programs. The auditor must review the applicable documents considered necessary to perform the audit:
1. The agreement between USAID and the contractor.
2. The sub-agreements between the contractor and other implementing entities, as applicable.
3. Contracts and subcontracts with third parties, if any.
4. The budgets, implementation letters, and written procedures approved by USAID.
5. USAID Automated Directives System Chapter 636 – “Program Funded Advances”.
6. 2 CFR 200 Subpart F on audit and 2 CFR 700 on Cost Principles.
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7. Federal Acquisition Regulation (FAR), Part 31, Contract Cost Principles and Procedures.
8. USAID Acquisition Regulation (AIDAR), which supplement the FAR.
9. Mandatory Standard Provisions for U.S. and Non-U.S. Non-governmental Grantees
(USAID Automated Directives System, Chapter 303, Grants and Cooperative Agreements to Non-Government Organizations).
10. Standard Provisions Annex for Agreements with Foreign Governments (USAID Automated Directives System, Chapter 350, Grants to Foreign Governments).
11. All program financial and progress reports; and charts of accounts, organizational charts;
accounting systems descriptions; procurement policies and procedures; and receipt, warehousing and distribution procedures for materials, as necessary to successfully complete the required work.
12. Any previous audits, financial reviews, etc., that directly relate to the objectives of the audit.
B. Fund Accountability Statement
The auditor must examine the fund accountability statement1 for USAID programs including the budgeted amounts by category and major items; the revenues received from USAID for the period covered by the audit; the costs reported by the recipient as incurred during that period; and the commodities and technical assistance directly procured by USAID for the recipient's use. The fund accountability statement must include all USAID funds identified by each specific program or agreement. The revenues received from USAID less the costs incurred, after considering any reconciling items, must reconcile with the balance of cash-on-hand or in bank accounts2. The fund accountability statement must not include cost-sharing/matching contributions provided from the recipient's own funds or in-kind.
The audit firm may not prepare or assist the recipient in preparing the fund accountability statement when the same audit firm will then perform the audit. If a third party prepares or assists the recipient in preparing the fund accountability statement from the books and records maintained by the recipient, then the recipient must accept the responsibility for the statement’s accuracy before the audit commences.
The fund accountability statement must separately identify those revenues and costs applicable to each specific USAID agreement. The audit must evaluate program implementation actions and accomplishments to determine whether specific costs incurred are allowable, allocable, and reasonable under the agreement terms and applicable cost principles, and to identify areas where
1 A "fund accountability statement" is a financial statement that presents USAID contractor's revenues, costs incurred, cash balance of funds (after considering reconciling items), and commodities directly procured by USAID that were provided by USAID agreements.
The opinion on the fund accountability statement must comply with Statement on Auditing Standard SAS No. 62 (AU623).
2 If the contractor does not receive any advances from USAID, i.e., it operates on a reimbursement basis, then the contractor will not hold any balances of USAID funds.
15 | P a g e fraud and illegal acts have occurred or are likely to have occurred as a result of inadequate internal control. At a minimum, the auditors must:
1. Review direct and indirect costs billed to and reimbursed by USAID and costs incurred but pending reimbursement by USAID, identifying and quantifying any questioned costs. All costs that are not supported with adequate documentation or are not in accordance with the agreement terms must be reported as questioned. Questioned costs that are pending reimbursement by USAID must be identified in the notes to the fund accountability statement as not reimbursed by USAID.
2. Questioned costs must be presented in the fund accountability statement in two separate categories. Ineligible costs that are explicitly questioned because they are unreasonable, prohibited by the agreements or applicable laws and regulations, or not program related. In addition, if a contractor was required to place USAID funds in an interest-bearing account but did not, then the imputed interest that would have been earned is also classified as an ineligible cost. Unsupported costs are not supported with adequate documentation or did not have required prior approvals or authorizations. All questioned costs resulting from instances of noncompliance with agreement terms and applicable laws and regulations must be included as findings in the report on compliance. Also, the notes to the fund accountability statement must briefly describe the questioned costs and must be cross-referenced to any corresponding findings in the report on compliance.
3. Review general and program ledgers to determine whether costs incurred were properly recorded. Reconcile direct costs billed to, and reimbursed by, USAID to the program and general ledgers.
4. Review the procedures used to control the funds, including their channeling to contracted financial institutions or other implementing entities. Review the bank accounts and the controls on those bank accounts. Perform positive confirmation of balances, as necessary.
5. Determine whether advances of funds were justified with documentation, including reconciliations of funds advanced, disbursed, and available. The auditors must ensure that all funding received by the contractor from USAID was appropriately recorded in the contractor's accounting records and that those records were periodically reconciled with information provided by USAID.
6. Determine whether program income was added to funds used to further eligible project or program objectives, to finance the non-federal share of the project or program, or deducted from program costs, in accordance with USAID regulations, other implementing guidance, or the terms and conditions of the award.
7. Review procurement procedures to determine whether sound commercial practices including competition were used, reasonable prices were obtained, and adequate controls were in place over the qualities and quantities received.
8. Review direct salary charges to determine whether salary rates are reasonable for that position, in accordance with those approved by USAID when USAID approval is required, and supported by appropriate payroll records. Determine if overtime is charged to the program and whether it is allowable under the terms of the agreements. Determine whether allowances and fringe benefits received by employees are in accordance with the
16 | P a g e agreements and applicable laws and regulations. The auditors must question unallowable salary charges in the fund accountability statement.
9. Review travel and transportation charges to determine whether they are adequately supported and approved. Travel charges that are not supported with adequate documentation or not in accordance with agreements and regulations must be questioned in the fund accountability statement.
10. Review commodities (e.g., supplies, materials, vehicles, equipment, food products, tools, etc.) procured by the contractor as well as those directly procured by USAID for the contractor's use. The auditors must determine whether commodities exist or were used for their intended purposes in accordance with the terms of the agreements, and whether control procedures exist and have been placed in operation to adequately safeguard the commodities. As part of the procedures to determine if commodities were used for intended purposes, the auditors must perform end-use reviews for an appropriate sample of all commodities based on the control risk assessment (see section IV.D. of this statement of work). End-use reviews would normally include site visits to verify that commodities exist or were used for their intended purposes in accordance with the terms of the agreements. When conducting end-use reviews, the auditors must ensure that commodities are marked in accordance with grant or contract requirements. The cost of all commodities whose existence or proper use in accordance with the terms of the agreements cannot be verified must be questioned in the fund accountability statement. (The auditor should determine the cost of commodities based on supporting documentation available from the contractor or USAID, as appropriate).
11. Review technical assistance and services procured by the contractor. The auditors must determine whether technical assistance and services were used for their intended purposes in accordance with the terms of the agreements. The cost of technical assistance and services not properly used in accordance with the terms of the agreements must be questioned in the fund accountability statement.
If the technical assistance and services were contracted by the contractor from a non-U.S.
contractor, the auditors are still responsible for determining whether technical assistance and services were used for their intended purposes in accordance with the terms of the agreements. However, the auditors are not responsible for performing additional audit steps for the costs incurred under the technical assistance and services agreements, since either USAID or a cognizant U.S. Government agency is responsible for contracting for audits of these costs.
12. For final close-out audits, review unliquidated advances to the contractor and pending reimbursements by USAID. Ensure that the contractor has returned any excess cash to USAID. Also, ensure that all assets (inventories, fixed assets, commodities, etc.) procured with program funds were disposed of in accordance with the terms of the agreements. The auditors should present, as an annex to the fund accountability statement, the balances and details of final inventories of nonexpendable property acquired under the agreements. This inventory must indicate which items were titled to the U.S. Government and which were titled to other entities. These closeout audit procedures must be performed for any award that expires during the period audited.
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The fund accountability statement must separately disclose the financial information (revenues, costs, etc.) for each agreement, and must identify the USAID missions/offices that provided funding for each agreement. Questioned costs, and internal control and compliance findings of any audits of sub-recipients must be reported in the contractor’s financial audit using the same treatment and procedures as the contractor’s own questioned costs and findings.
The auditors must generally express a single opinion on the fund accountability statement that includes more than one agreement with USAID. Auditors must not express separate opinions on fund accountability statements of each agreement or program unless specifically requested to do so by the USAID mission.
The fund accountability statement is the basic financial statement to be audited when indirect cost rates are not used.
All amounts in the financial audit report must be stated in U.S. dollars. The auditors should indicate the exchange rate(s) used in the notes to the fund accountability statement.
C. Compliance with the National Technical Assistance (NTA)
Perform a review of Auditee’s compliance with the National Technical Assistance (NTA) Salary Scale and Implementation Guideline. The Auditor must as applicable review the following documents before commencing this review:
(1) The Government of the Islamic Republic of Afghanistan’s (GIRoA) Ministry of Finance’s (MoF) “Self-Reliance through Mutual Accountability Framework (SMAF)” report and requisite annexes effective September 5, 2015.;
(2) Implementing Partner (IP) letter issued by the Office of Acquisition and Assistance (OAA) #OAA-IP-2016-001 dated 7/7/2016, entitled “National Technical Assistance Scale and Guidelines”, IPs Letter #OAA-IP-2016-001 dated 7/29/2016, IPs Letter #OAA-IP-2017-004 dated 8/17/2017, and any associated USAID Questions and Answers documentation;
(3) MoF’s National Technical Assistance Salary Scale and Implementation Guideline clarification notes 1 and 2 and,
(4) MoF Website hosted at http://www.budgetmof.gov.af/index.php/en/nta/about-nta/83-directorate-general-budget The auditor must as applicable conduct a review of the recipient’s files, including hiring and salary documentation, to verify compliance with salary and hiring procedures, NTA-related provisions, USAID guidance and instructions, and GIRoA legal requirements.
The auditor must perform the following categorical reviews:
a. Review and determine if awardee has complied with the NTA hiring requirements outlined in the respective provisions, USAID/Afghanistan’s policy, and GIRoA rules and regulations;
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b. Review and determine if internal procedures were established by the awardee to ensure compliance with NTA policies and guidelines;
c. Verify if recipient has implemented and followed the procedures designed to ensure that hiring, position classifications and salaries are in compliance with applicable guidelines and regulations;
d. Review and determine if adjustments to salaries for “embedded” staff were implemented as per the Mission and GIRoA guidelines;
e. Verify that internal employees assuming new roles after the issuance of guidance to partners were properly assigned salaries in compliance with NTA guidelines;
f. Verify that any exceptions to the policy were justified, documented and properly approved;
g. Verify that internal salary structure is consistent with the NTA classification system and any deviations are properly documented and have received prior approval.
h. For any instance of any non-compliance with NTA policies and procedures, the Auditor must report the following:
1. Name of recipient, hiring mechanism, position title and description, salary amount and classification;
2. The circumstances behind the non-compliance;
3. Internal control deficiency or non-compliance with internal control policies and procedures;
4. Provide recommendations to address the internal control deficiency or non-compliance with internal control policies and procedures.
If red flags are identified, the auditor should select a larger sample of source documents for examination. As part of this examination, reference must be made back to the source of the document (for example, actual verification of source documents with the vendor).
D. Cost Sharing/Matching Contribution Schedule (If Applicable)
USAID agreements may require contributions by the recipient. USAID and recipient awards may establish a life-of-project budget or an annual budget for the cost sharing/matching contributions.
In either case, the review consists principally of inquiries of recipient personnel and analytical procedures applied to financial data supporting the cost sharing/counterpart contributions Table.
The auditors may prepare or assist the recipient in preparing the cost sharing/matching contributions schedule from the books and records maintained by the recipient. The recipient must, however, accept responsibility for the schedule's accuracy before the review commences.
For an agreement with a life-of-project budget for cost-sharing/matching contributions, it is not possible to determine whether the contributions have been made as required until the agreement ends. Nonetheless, USAID and the recipient need reliable information to monitor actual cost-sharing/matching contributions throughout the life of the agreement.
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The auditors will review the cost sharing/matching contributions schedule to determine if the schedule is fairly presented in accordance with the basis of accounting used by the recipient to prepare the schedule. The auditors must question all cost-sharing/matching contributions that are either ineligible or unsupported costs. An ineligible cost is unreasonable, prohibited by the agreements or applicable laws and regulations, or not program related. An unsupported cost lacks adequate documentation or does not have required prior approvals or authorizations. All questioned costs must be briefly described in the notes to the cost sharing/matching contributions.
In addition, material questioned costs must be included as findings in the report on compliance.
Notes to the cost sharing/matching contributions schedule must be cross-referenced to the corresponding findings in the report on compliance. Also, significant deficiencies in internal control related to cost-sharing/matching contributions must be set forth as findings in the report on internal control.
In addition, for closeout the auditors will review the cost-sharing/matching contributions schedule to determine if the recipients provided such contributions in accordance with the terms of the agreement. If actual contributions were less than budgeted contributions, the shortfall will be identified in the appropriate column of the cost sharing/matching contributions schedule.
E. Internal Controls
The auditors must review and evaluate the contractor's internal controls related to USAID programs to obtain a sufficient understanding of the design of relevant control policies and procedures and whether those policies and procedures have been placed in operation. The auditor's understanding of the internal controls must be documented in the audit documentation files.
Auditors must prepare the report required by the Guide (Appendix 2), identifying any significant deficiencies or material weaknesses in the design or operation of internal control. A material weakness is a deficiency, or combination of deficiencies, in internal controls, such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented or detected and corrected on a timely basis. A significant deficiency is a deficiency, or combination of deficiencies, in internal control that is less severe than a material weakness but that is important enough to merit attention by those charged with governance. Any significant deficiencies or material weaknesses must be set forth in the report as “findings”. Any other matters related to internal controls – such as suggestions for improving operational or administrative efficiency, effectiveness, or control deficiencies that are not significant deficiencies or material weaknesses – may be reported in a separate management letter to the recipient and referred to in the report on internal control. A copy of the management letter should be provided to the USAID/Afghanistan along with the audit report.
The major internal control components to be studied and evaluated include, but are not limited to, the controls related to each revenue and expense account on the fund accountability statement.
The auditors must:
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1. Obtain an understanding of the design of the internal control related to USAID programs and determine whether they have been placed in operation.
2. Assess inherent risk, control risk, and determine the detection risk. Inherent risk is the susceptibility of an assertion, such as an account balance, to a misstatement that could be material, either individually or when aggregated with other misstatements, assuming that there are no related controls. Control risk is the risk that a misstatement that could occur in a relevant assertion and that could be material, either individually or when aggregated with other misstatements, will not be prevented or detected on a timely basis by the entity's internal control. Detection risk is the risk that the auditor will not detect a material misstatement that exists in an assertion. Detection risk is based upon the effectiveness of an auditing procedure and the auditor’s application of that procedure.
3. Summarize the risk assessments for each assertion in the audit documentation file. The risk assessments must consider the following broad categories under which each assertion should be classified: (a) existence or occurrence; (b) completeness; (c) rights and obligations; (d) valuation or allocation; and (e) presentation and disclosure. At a minimum, the audit documentation files must identify the name of the account or assertion, the account balance or the amount represented by the assertion, the assessed level of inherent risk (high, moderate, or low), the assessed level of control risk (high, moderate, or low), the combined risk (high, moderate, or low), and a description of the nature, extent, and timing of the tests performed based on the combined risk. These summary audit documentation files must be cross-indexed to the supporting audit documentation files that contain the detailed analysis of the fieldwork. If control risk is evaluated at less than the maximum level (high), then the basis for the auditor's conclusion must be documented in the audit documentation files.
4. Evaluate the control environment, the adequacy of the accounting systems, and control procedures. Emphasis must be placed on the policies and procedures that pertain to the contractor’s ability to record, process, summarize, and report financial data consistent with the assertions embodied in each account of the fund accountability statement. This evaluation must include, but not be limited to, the control systems for:
a. Ensuring that charges to the program are proper and supported;
b. Managing cash on hand and in bank accounts;
c. Procuring goods and services;
d. Managing inventory and receiving functions;
e. Managing personnel functions such as timekeeping, salaries, and benefits;
f. Managing and disposing of commodities (such as vehicles, equipment, and tools, as well as other commodities) purchased either by the program or directly by USAID; and
g. Ensuring compliance with agreement terms and applicable laws and regulations that collectively have a material impact on the fund accountability statement. The results of this evaluation must be contained in the audit documentation section
21 | P a g e described in section IV.E of this Statement of Work and presented in the compliance report.
5. Evaluate internal control established to ensure compliance with cost sharing/matching contribution requirements, if applicable, including both provision and management of the contributions
6. Include in the study and evaluation other policies and procedures that may be relevant if they pertain to data the auditors use in applying auditing procedures. This may include, for example, policies and procedures that pertain to nonfinancial data that the auditor uses in analytical procedures.
F. Compliance with Agreement Terms and Applicable Laws and Regulations
In fulfilling the audit requirement to determine compliance with agreement terms and applicable laws and regulations related to USAID programs, the auditors must follow the reporting standards contained in GAGAS for reporting on…
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