Finding 2022-002: Reportable Finding Considered a Significant Deficiency ? Procurement compliance Program Name: Market Access Plan Assistance listing #: 10.601 Federal Awarding Agency: U.S. Department of Agriculture Award Number: 12-4336-0-3-999 Compliance Requirement: Procurement, Suspension, and Debarment Criteria: According to 2 CFR 200.318(a) non-federal entities must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of 2 CFR 200.318 through 200.327, for the acquisition of property or services required under a Federal award. Condition: During our testing of vendor procurement compliance, we noted the entity had a procurement policy in line with the federal award?s specific procurement guidelines but not in line with standards of 2 CFR 200.318 through 200.327. In particular, the policy did not address methods of procurement based on micro-purchase, small purchase, and simplified acquisition purchase thresholds, circumstances in which noncompetitive procurement could be used, and procedures for verifying that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause: The auditee was not aware of the requirements outlined in 2 CFR 200.318 through 200.327, and believed the contracting guidelines outlined for their specific award were sufficient. Effect: The auditee was not in compliance with procurement policies outlined in of 2 CFR 200.318 through 200.327. There was a lack of full and open competition and auditee did not ensure the vendors with which it planned to enter into a covered transaction were not debarred, suspended, or otherwise excluded. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization adopt an updated procurement policy in line with 2 CFR 200 requirements and ensure all staff involved in the acquisition of property or services charged to federal grants are aware of relevant procurement requirements. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
Finding 2022-003: Reportable Finding Considered a Significant Deficiency ? Disbursement cutoff Program Name: Market Access Plan Assistance listing #: 10.601 Federal Awarding Agency: U.S. Department of Agriculture Award Number: 12-4336-0-3-999 Compliance Requirement: Allowable Costs/Principles Criteria: According to 2 CFR 200.403, costs must meet a set of criteria in order to be allowable under the federal award, including being determined in accordance with generally accepted accounting principles (GAAP). According to GAAP, expenses must be recognized in the period incurred. Condition: During our testing of allowable cost principles compliance, out of 40 selections, we noted one that was partially expensed in the incorrect year. Cause: The invoice for this selection included services performed in both fiscal year 2022 and 2023, but the entire invoice balance was expensed in 2022. Effect: The auditee was not in compliance with allowable cost principles outlined in of 2 CFR 200.403 resulting in program expenses being recognized in the incorrect year. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization adopt procedures for more detailed review of invoices prior to recognizing expenses. Invoices should be reviewed in detail to determine when the services were performed to therefore recognize the expense appropriately, rather than recognizing invoices upon receipt or upon payment. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
Finding 2022-004: Reportable Finding Considered a Significant Deficiency ? Reporting compliance Program Name: Market Access Plan Assistance listing #: 10.601 Federal Awarding Agency: U.S. Department of Agriculture Award Number: 12-4336-0-3-999 Compliance Requirement: Reporting Criteria: According to 7 CFR 1485.22(d), participants are required to submit regular financial and performance reports in accordance with their agreement. For non-local travel, participants are required to submit trip reports within 45 calendar days after the completion of travel. Condition: During our testing of reporting compliance, out of a sample size of three reports, one trip report was submitted after the required 45 days upon return from the trip. Cause: The auditee is aware of the compliance requirement but due to an administrative oversight, the trip report was submitted late. Effect: The auditee was not in compliance with reporting requirements outlined in of 7 CFR 1485.22 resulting in untimely federal award data reporting. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization update their policies and procedures surrounding the submission of reports, and specifically trip reports, to ensure the appropriate individual(s) know their roles in relation to timely trip reporting and are aware of strict reporting deadlines. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
Finding 2022-002: Reportable Finding Considered a Significant Deficiency ? Procurement compliance Program Name: Market Access Plan Assistance listing #: 10.601 Federal Awarding Agency: U.S. Department of Agriculture Award Number: 12-4336-0-3-999 Compliance Requirement: Procurement, Suspension, and Debarment Criteria: According to 2 CFR 200.318(a) non-federal entities must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of 2 CFR 200.318 through 200.327, for the acquisition of property or services required under a Federal award. Condition: During our testing of vendor procurement compliance, we noted the entity had a procurement policy in line with the federal award?s specific procurement guidelines but not in line with standards of 2 CFR 200.318 through 200.327. In particular, the policy did not address methods of procurement based on micro-purchase, small purchase, and simplified acquisition purchase thresholds, circumstances in which noncompetitive procurement could be used, and procedures for verifying that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Cause: The auditee was not aware of the requirements outlined in 2 CFR 200.318 through 200.327, and believed the contracting guidelines outlined for their specific award were sufficient. Effect: The auditee was not in compliance with procurement policies outlined in of 2 CFR 200.318 through 200.327. There was a lack of full and open competition and auditee did not ensure the vendors with which it planned to enter into a covered transaction were not debarred, suspended, or otherwise excluded. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization adopt an updated procurement policy in line with 2 CFR 200 requirements and ensure all staff involved in the acquisition of property or services charged to federal grants are aware of relevant procurement requirements. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
Finding 2022-003: Reportable Finding Considered a Significant Deficiency ? Disbursement cutoff Program Name: Market Access Plan Assistance listing #: 10.601 Federal Awarding Agency: U.S. Department of Agriculture Award Number: 12-4336-0-3-999 Compliance Requirement: Allowable Costs/Principles Criteria: According to 2 CFR 200.403, costs must meet a set of criteria in order to be allowable under the federal award, including being determined in accordance with generally accepted accounting principles (GAAP). According to GAAP, expenses must be recognized in the period incurred. Condition: During our testing of allowable cost principles compliance, out of 40 selections, we noted one that was partially expensed in the incorrect year. Cause: The invoice for this selection included services performed in both fiscal year 2022 and 2023, but the entire invoice balance was expensed in 2022. Effect: The auditee was not in compliance with allowable cost principles outlined in of 2 CFR 200.403 resulting in program expenses being recognized in the incorrect year. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization adopt procedures for more detailed review of invoices prior to recognizing expenses. Invoices should be reviewed in detail to determine when the services were performed to therefore recognize the expense appropriately, rather than recognizing invoices upon receipt or upon payment. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
Finding 2022-004: Reportable Finding Considered a Significant Deficiency ? Reporting compliance Program Name: Market Access Plan Assistance listing #: 10.601 Federal Awarding Agency: U.S. Department of Agriculture Award Number: 12-4336-0-3-999 Compliance Requirement: Reporting Criteria: According to 7 CFR 1485.22(d), participants are required to submit regular financial and performance reports in accordance with their agreement. For non-local travel, participants are required to submit trip reports within 45 calendar days after the completion of travel. Condition: During our testing of reporting compliance, out of a sample size of three reports, one trip report was submitted after the required 45 days upon return from the trip. Cause: The auditee is aware of the compliance requirement but due to an administrative oversight, the trip report was submitted late. Effect: The auditee was not in compliance with reporting requirements outlined in of 7 CFR 1485.22 resulting in untimely federal award data reporting. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization update their policies and procedures surrounding the submission of reports, and specifically trip reports, to ensure the appropriate individual(s) know their roles in relation to timely trip reporting and are aware of strict reporting deadlines. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.