Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.
Finding 2023-003 – Procurement, Non-compliance (Material Weakness)
Federal programs: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster
Criteria: The Federal Government requires that all procurement transactions for the acquisition of
property or services required under a Federal award must be conducted in a manner providing full
and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section
200.320. Non-federal entities must also ensure that every purchase order or other contract includes
provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to
2 CRF Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards”. In
addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards
establish and maintain internal controls designed to reasonably ensure compliance with Federal laws,
regulations, and program compliance requirements.
Condition: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Context: During our testing of procurement for the Research and Development Cluster, we noted
that the Organization did not provide adequate documentation of price or rate quotations from a
qualified number of sources for 3 of 40 items tested that met the small purchase threshold. For an
additional 4 of the 40 items that met the small purchase threshold and were single sourced, the
Organization could not provide adequate documentation of the sole source justification being
documented prior to the purchase being made. The sample was not statistically valid.
During our testing of procurement for Coronavirus State and Local Fiscal Recovery Funds ALN
21.027, we noted that 3 of the 3 contracts entered into did not include the proper contract flow-down
provisions. Additionally, 2 of the 3 contracts that met the small purchase threshold and were sole
sourced did not include adequate documentation of sole source justification prior to the purchase.
Cause: The Organization did not properly identify certain purchase orders or other contracts as
federal award transactions subject to procurement regulations.
Effect: Internal controls were not properly implemented to reduce the risk of noncompliance and the
Organization was not in compliance with Federal procurement requirements.Questioned costs: None
Repeat finding: No
Recommendation: We recommend management review internal controls over identification of
federal contracts for adequacy and ensure internal controls over the procurement process are
properly implemented.
Views of responsible officials: Management agrees with the finding and the auditors’
recommendation. See Corrective Action Plan at the end of the report.