Audit 18316

Federal Grants Management - Procurement Policy ? Suspension and Debarment Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: Michigan Department of Treasury Award Period: March 1, 2021 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Context There were five transactions that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on all five items tested that Dickinson County, Michigan was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: Michigan Department of Treasury Award Period: March 1, 2021 ? December 31, 2024 Type of Finding: Significant deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement 2 CFR 200.320(a)(2)(ii) requires that "The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations." 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. Condition The County did not follow controls related to ensuring procurement policies were followed. Questioned Costs None. Context There were 55 transactions that exceeded procurement thresholds during the granting period. The sample size selected tested was 19. During our testing, it was noted on 6 of the 19 items tested that Dickinson County, Michigan was not following the requirements under the adopted procurement policies. Cause The County did not follow the requirements under the adopted procurement policies. Effect The County is not in compliance with procurement requirements. Contracts for construction, non- construction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Repeat Finding No. Recommendation We recommend the County review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials There is no disagreement with the finding.

Federal Grants Management - Procurement Policy ? Suspension and Debarment Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: Michigan Department of Treasury Award Period: March 1, 2021 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Context There were five transactions that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on all five items tested that Dickinson County, Michigan was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: Michigan Department of Treasury Award Period: March 1, 2021 ? December 31, 2024 Type of Finding: Significant deficiency in Internal Control over Compliance and Other Matter Criteria or Specific Requirement 2 CFR 200.320(a)(2)(ii) requires that "The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations." 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. Condition The County did not follow controls related to ensuring procurement policies were followed. Questioned Costs None. Context There were 55 transactions that exceeded procurement thresholds during the granting period. The sample size selected tested was 19. During our testing, it was noted on 6 of the 19 items tested that Dickinson County, Michigan was not following the requirements under the adopted procurement policies. Cause The County did not follow the requirements under the adopted procurement policies. Effect The County is not in compliance with procurement requirements. Contracts for construction, non- construction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Repeat Finding No. Recommendation We recommend the County review procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials There is no disagreement with the finding.