Audit 322559

Criteria: According to 2 CFR 200.320(a)(2) price quotations must be obtained from an adequate number of qualified sources for the acquisition of property or services for which the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. Condition: During our testing of vendor procurement compliance, we noted price quotations were not obtained for one of the three selected vendors with aggregate purchases exceeding the micro-purchase threshold. Cause: Per discussion with Management, they have been working with this vendor for years and when originally contracted, the amount was below the micropurchase threshold. Staff were not aware that they needed to monitor expenditures after the initial contract to ensure that once expenditures exceed this threshold, proper procurement policies are then followed. Effect: The auditee did not obtain price quotations for purchases from one vendor exceeding the micro-purchase threshold as required by 2 CFR 200.320(a)(2). Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization revisit its procurement policy and ensure all staff involved in the acquisition of property or services charged to federal grants are aware of relevant procurement requirements. Staff should monitor vendors that start off as small purchases to ensure proper policies are followed once procurement thresholds are met.

Criteria: According to 2 CFR 200.303(a), Organizations must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing of cash draws, it was noted that the same individual was preparing, reviewing, and initiating cash draws for the Organization. A similar situation was noted in our testing of internal controls over reporting in that the same individual was preparing, reviewing, and submitting the financial reports. Cause: Per discussion with Management, due to turnover and transitions within the accounting department and outsourced accountants there was a period of time where segregation of duties was not maintained. Effect: The internal controls over cash draws and reporting were not in compliance with federal guidelines. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization take steps to ensure proper segregation of duties and implement alternatives if or when sufficient staffing is not available in traditional roles.

Criteria: According to 2 CFR 200.320(a)(2) price quotations must be obtained from an adequate number of qualified sources for the acquisition of property or services for which the aggregate dollar amount is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. Condition: During our testing of vendor procurement compliance, we noted price quotations were not obtained for one of the three selected vendors with aggregate purchases exceeding the micro-purchase threshold. Cause: Per discussion with Management, they have been working with this vendor for years and when originally contracted, the amount was below the micropurchase threshold. Staff were not aware that they needed to monitor expenditures after the initial contract to ensure that once expenditures exceed this threshold, proper procurement policies are then followed. Effect: The auditee did not obtain price quotations for purchases from one vendor exceeding the micro-purchase threshold as required by 2 CFR 200.320(a)(2). Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization revisit its procurement policy and ensure all staff involved in the acquisition of property or services charged to federal grants are aware of relevant procurement requirements. Staff should monitor vendors that start off as small purchases to ensure proper policies are followed once procurement thresholds are met.

Criteria: According to 2 CFR 200.303(a), Organizations must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing of cash draws, it was noted that the same individual was preparing, reviewing, and initiating cash draws for the Organization. A similar situation was noted in our testing of internal controls over reporting in that the same individual was preparing, reviewing, and submitting the financial reports. Cause: Per discussion with Management, due to turnover and transitions within the accounting department and outsourced accountants there was a period of time where segregation of duties was not maintained. Effect: The internal controls over cash draws and reporting were not in compliance with federal guidelines. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization take steps to ensure proper segregation of duties and implement alternatives if or when sufficient staffing is not available in traditional roles.