Grant Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Number and Year: 2023 Assistance Listing #: 21.027 Federal Agency: US Department of Treasury CONDITION: We identified that payments were made in excess of contracted amounts. CONTEXT: Specifically, a contract was executed with a vendor delineating specific prices for goods in alignment with a federal contract established between the vendor and the General Services Administration (GSA). The vendor is a voluntary participant in the GSA Cooperative Purchasing Program. During fiscal year 2023, amounts paid in excess of contractually stipulated prices totaled $30,851. CRITERIA: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.404 states, in part, that: "A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award. (c) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award. (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award's cost." QUESTIONED COSTS: $30,851 CAUSE: Procedures were not in place to verify that disbursements aligned with contractually stipulated amounts. EFFECT: The County's use of funds deviated from required cost principles. REPEAT FINDING: No RECOMMENDATION: Officials should seek reimbursement or a credit for amounts charged in excess of the GSA price. Additionally, officials should establish and follow procedures mandating a review and recalculation of all invoice payments. This review process should ensure that prices align with amounts agreed to in the executed contract. In instances where discrepancies are identified, officials should engage with the vendor and relevant state and federal agencies associated with the contract to determine that payments are made only to costs charged in accordance with the associated contract. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: The County Commission will seek reimbursement for the amounts paid in excess of contractually stipulated prices directly from the vendor.
Grant Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Number and Year: 2023 Assistance Listing #: 21.027 Federal Agency: US Department of Treasury CONDITION: We identified that payments were made in excess of contracted amounts. CONTEXT: Specifically, a contract was executed with a vendor delineating specific prices for goods in alignment with a federal contract established between the vendor and the General Services Administration (GSA). The vendor is a voluntary participant in the GSA Cooperative Purchasing Program. During fiscal year 2023, amounts paid in excess of contractually stipulated prices totaled $30,851. CRITERIA: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.404 states, in part, that: "A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award. (c) The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award. (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award's cost." QUESTIONED COSTS: $30,851 CAUSE: Procedures were not in place to verify that disbursements aligned with contractually stipulated amounts. EFFECT: The County's use of funds deviated from required cost principles. REPEAT FINDING: No RECOMMENDATION: Officials should seek reimbursement or a credit for amounts charged in excess of the GSA price. Additionally, officials should establish and follow procedures mandating a review and recalculation of all invoice payments. This review process should ensure that prices align with amounts agreed to in the executed contract. In instances where discrepancies are identified, officials should engage with the vendor and relevant state and federal agencies associated with the contract to determine that payments are made only to costs charged in accordance with the associated contract. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: The County Commission will seek reimbursement for the amounts paid in excess of contractually stipulated prices directly from the vendor.