Audit 315329

Federal Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 1505-0271; 2021 Pass-Through Agency : N/A Pass-Through Number(s) : N/A Award Period: March 3, 2021 – December 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318) requires the non-federal entity to maintain records sufficient to detail the history of procurement. Additionally, federal guidelines require the entity to have procedures documented to verify the vendor of a covered transaction (over $25,000) is not debarred, suspended, or otherwise excluded from participating in the transaction, prior to entering into a covered transaction. Condition: Certain purchases were not adequately documented supporting the lack of traditional procurement processes being required. Additionally, the County did not complete suspension and debarment procedures for covered transactions. Questioned costs : None. Context : In the testing of 4 of 7 procurement transactions, the County did not maintain appropriate documentation to support the history of procurement, which should include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, in the testing of 5 of 5 covered transactions, the County did not complete the required suspension and debarment procedures prior to purchase. Cause: Timing of implementation of new controls occurred after some transactions had already been procured. Effect: Lack of internal control procedures can lead to noncompliance with grant requirements. Repeat finding : This is a repeat of prior year finding 2022-006. Recommendation: We recommend ensuring procurement procedures are complete and in accordance with Uniform Grant Guidance for any federal purchases, and available for all departments. These procedures should include verifying vendors or contractors are not suspended or debarred from doing business, prior to contracting with them, and maintaining documentation of this. The County should consider adding a Federal Procurement Checklist that covers the applicable Uniform Guidance requirements that should be completed when making purchases and retained with other procurement documents. Views of responsible officials: There is no disagreement with the audit finding.

Federal Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 1505-0271; 2021 Pass-Through Agency : N/A Pass-Through Number(s) : N/A Award Period: March 3, 2021 – December 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318) requires the non-federal entity to maintain records sufficient to detail the history of procurement. Additionally, federal guidelines require the entity to have procedures documented to verify the vendor of a covered transaction (over $25,000) is not debarred, suspended, or otherwise excluded from participating in the transaction, prior to entering into a covered transaction. Condition: Certain purchases were not adequately documented supporting the lack of traditional procurement processes being required. Additionally, the County did not complete suspension and debarment procedures for covered transactions. Questioned costs : None. Context : In the testing of 4 of 7 procurement transactions, the County did not maintain appropriate documentation to support the history of procurement, which should include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Additionally, in the testing of 5 of 5 covered transactions, the County did not complete the required suspension and debarment procedures prior to purchase. Cause: Timing of implementation of new controls occurred after some transactions had already been procured. Effect: Lack of internal control procedures can lead to noncompliance with grant requirements. Repeat finding : This is a repeat of prior year finding 2022-006. Recommendation: We recommend ensuring procurement procedures are complete and in accordance with Uniform Grant Guidance for any federal purchases, and available for all departments. These procedures should include verifying vendors or contractors are not suspended or debarred from doing business, prior to contracting with them, and maintaining documentation of this. The County should consider adding a Federal Procurement Checklist that covers the applicable Uniform Guidance requirements that should be completed when making purchases and retained with other procurement documents. Views of responsible officials: There is no disagreement with the audit finding.