Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.
Condition: The County's policies do not contain all of the required procurement policies as they relate to federal awards.
Cause: The County was not aware of the change when the regulations were revised and was not able to take action on it when they were made aware of the change.
Criteria: Title 2, Part 200, Subpart D - Post Federal Award Requirements, 200.318(a) The non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part and 200.318(c)(1). The non-federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Standards of conduct must provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the non-federal entity. (2) If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-federal entity must also maintain written standards of conduct covering organizational conflicts of interest.
Effect: Not having such policies and procedures in place, may increase the risk of procuring items that are not allowable, not procuring items through fair competition, and/or overpaying for items.
Perspective Information: The policies that were in place were particular to the Road and Bridge fund and somewhat met the requirements for dollar thresholds and when quotes vs. bids are required. However, the policies should be effective government-wide for all federal awards. There are similar issues with conflict of interest policies not entirely conforming to federal regulations.
Recommendations: We recommend that the County's policies and procedures are updated to comply with the Code of Federal Regulations. It is also recommended that a review of the Code of Federal Regulations occur on a periodic basis, as well as periodic communications with the County's attorney and the Idaho Association of Counties for any changes that may affect the County.
View of Responsible Officials and Planned Corrective Actions: The County agrees with this finding. In January 2023, the County created a separate Procurement Policy that should comply with the Code of Federal Regulations. See Corrective Action Plan.