Audit 34202

Federal Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: March 3, 2021 ? December 31, 2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318) requires the non-federal entity to maintain records sufficient to detail the history of procurement. In the case of an emergency or sole source purchase, proper documentation of this must be maintained. Additionally, federal guidelines require the entity to have procedures documented to verify the vendor of a covered transaction (over $25,000) is not debarred, suspended, or otherwise excluded from participating in the transaction, prior to entering into a covered transaction. Condition: Purchases deemed ?sole source? purchases were not adequately documented supporting the lack of traditional procurement processes being required. Additionally, the County did not complete suspension and debarment procedures for covered transactions. Questioned costs: None. Context: In the testing of 5 of 6 procurement transactions, the County did not maintain appropriate documentation to support why they were noncompetitive purchases. Additionally, in the testing of 5 of 6 suspension and debarment eligible transactions, the County did not complete the required suspension and debarment procedures required for covered transactions. Cause: With new federal funding opportunities arising due to the COVID-19 pandemic, and new guidance related to those grants, grant personnel were not aware of these requirements. Effect: Lack of internal control procedures can lead to noncompliance with grant requirements. Repeat Finding: N/A Recommendation: We recommend ensuring procurement procedures are complete and in accordance with Uniform Grant Guidance for any federal purchases, and available for all departments. This procedure should include verifying vendors or contractors are not suspended or debarred from doing business, prior to contracting them, and maintaining documentation of this. The County should consider adding a Federal Procurement Checklist that covers the applicable Uniform Guidance requirements that should be completed when making purchases, and retained with other procurement documents. Views of responsible officials: There is no disagreement with the audit finding.

Federal Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: March 3, 2021 ? December 31, 2024 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318) requires the non-federal entity to maintain records sufficient to detail the history of procurement. In the case of an emergency or sole source purchase, proper documentation of this must be maintained. Additionally, federal guidelines require the entity to have procedures documented to verify the vendor of a covered transaction (over $25,000) is not debarred, suspended, or otherwise excluded from participating in the transaction, prior to entering into a covered transaction. Condition: Purchases deemed ?sole source? purchases were not adequately documented supporting the lack of traditional procurement processes being required. Additionally, the County did not complete suspension and debarment procedures for covered transactions. Questioned costs: None. Context: In the testing of 5 of 6 procurement transactions, the County did not maintain appropriate documentation to support why they were noncompetitive purchases. Additionally, in the testing of 5 of 6 suspension and debarment eligible transactions, the County did not complete the required suspension and debarment procedures required for covered transactions. Cause: With new federal funding opportunities arising due to the COVID-19 pandemic, and new guidance related to those grants, grant personnel were not aware of these requirements. Effect: Lack of internal control procedures can lead to noncompliance with grant requirements. Repeat Finding: N/A Recommendation: We recommend ensuring procurement procedures are complete and in accordance with Uniform Grant Guidance for any federal purchases, and available for all departments. This procedure should include verifying vendors or contractors are not suspended or debarred from doing business, prior to contracting them, and maintaining documentation of this. The County should consider adding a Federal Procurement Checklist that covers the applicable Uniform Guidance requirements that should be completed when making purchases, and retained with other procurement documents. Views of responsible officials: There is no disagreement with the audit finding.