Audit 303644

Federal Program: 594 Environmental Infrastructure Assistance Program (AL 12.U01): Procurement, Suspension, and Debarment Criteria: Per Uniform Guidance, “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 section 200.318 through 200.326. They must use their own documented procurement procedures, which reflect appliable 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. Furthermore, “Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: During testing, we noted that the City does not have a procurement policy in place that follows Uniform Guidance. Also, we noted that the City entered into two covered transactions with vendors who were not reviewed for suspension and debarment before entering into these transactions. Questioned Costs: None. Context: The City does not have a procurement policy that follows Uniform Guidance. Also, we tested two vendors who were not reviewed for suspension and debarment from a population of two. Cause: Management Oversight. Effect: The City is not in compliance with Uniform Guidance. Also, there is an increased risk of the City entering into a covered transaction with an entity that is suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: The City should implement a written procurement policy that follows Uniform Guidance. Furthermore, vendors should be reviewed for suspension and debarment before entering into a covered transaction. View of Responsible Officials: The City agrees with the recommendation.

Federal Program: 594 Environmental Infrastructure Assistance Program (12.U01); Reporting Criteria: The Uniform Guidance states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition: The City’s December 31, 2022 reporting package was not filed with the Federal Audit Clearinghouse within nine months of the City’s year end. Questioned Costs: None. Context: The City’s December 31, 2022 reporting package was not filed with the Federal Audit Clearinghouse within nine months of the City’s year end. Cause: Management oversight. Effect: The City is not in compliance with Uniform Guidance reporting requirements. Repeat Finding: No. Recommendation: The City’s audit should be completed within nine months of the fiscal year end to allow for timely submission of the data collection form and reporting package. View of Responsible Officials: The City agrees with the recommendation.

Federal Program: 594 Environmental Infrastructure Assistance Program (AL 12.U01): Procurement, Suspension, and Debarment Criteria: Per Uniform Guidance, “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 section 200.318 through 200.326. They must use their own documented procurement procedures, which reflect appliable 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. Furthermore, “Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: During testing, we noted that the City does not have a procurement policy in place that follows Uniform Guidance. Also, we noted that the City entered into two covered transactions with vendors who were not reviewed for suspension and debarment before entering into these transactions. Questioned Costs: None. Context: The City does not have a procurement policy that follows Uniform Guidance. Also, we tested two vendors who were not reviewed for suspension and debarment from a population of two. Cause: Management Oversight. Effect: The City is not in compliance with Uniform Guidance. Also, there is an increased risk of the City entering into a covered transaction with an entity that is suspended or debarred from receiving federal funds. Repeat Finding: No. Recommendation: The City should implement a written procurement policy that follows Uniform Guidance. Furthermore, vendors should be reviewed for suspension and debarment before entering into a covered transaction. View of Responsible Officials: The City agrees with the recommendation.

Federal Program: 594 Environmental Infrastructure Assistance Program (12.U01); Reporting Criteria: The Uniform Guidance states that an auditee must submit a data collection form and audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. Condition: The City’s December 31, 2022 reporting package was not filed with the Federal Audit Clearinghouse within nine months of the City’s year end. Questioned Costs: None. Context: The City’s December 31, 2022 reporting package was not filed with the Federal Audit Clearinghouse within nine months of the City’s year end. Cause: Management oversight. Effect: The City is not in compliance with Uniform Guidance reporting requirements. Repeat Finding: No. Recommendation: The City’s audit should be completed within nine months of the fiscal year end to allow for timely submission of the data collection form and reporting package. View of Responsible Officials: The City agrees with the recommendation.