Finding 2024-002: Reporting (Significant Deficiency)
Information on the Federal Program: 45.301 - Institute of Museum and Library Services
Criteria or Specific Requirement: As noted in 2 CFR §200.328 Monitoring and reporting program
performance (b)(1), “The non-Federal entity must submit performance reports at the interval required
by the Federal awarding agency”.
Condition: During the audit, we noted that the program reports selected for testing were not submitted
within the timeframe stipulated in the award agreement.
Cause: Management did not have effective internal controls in place to ensure that program reports
would be submitted timely and in line with requirements in the award agreement.
Effect or Potential Effect: Without established controls over reporting, there is a reasonable
possibility that the Museum would not detect noncompliance in the normal course of performing duties
and correct them in a timely manner.
Questioned Costs: None noted.
Context: 3 of the 3 program reports selected for testing were not submitted by the due date stipulated
in the award agreement.
Identification as a Repeat Finding, if Applicable: Not a repeat finding.
Recommendation: We recommend that management of the Museum ensure that all programmatic
reporting requirements are clearly communicated to program staff and managers. Controls should be
implemented to ensure that reports are prepared and submitted within a timely manner to the Federal
agency.
Finding 2024-003: Procurement (Significant Deficiency)
Information on the Federal Program: 45.301 - Institute of Museum and Library Services
Criteria: According to 2 CFR §200.303, the non-Federal entity must: (a) 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).
Additionally, according to 2 CFR §200.318 Procurement standards, the non-Federal entity must
maintain records sufficient to detail the history of procurement. These records will include, but are not
necessarily limited to, the following: Rationale for the method of procurement, selection of contract
type, contractor selection or rejection, and the basis for the contract price. Title 2, Subtitle A Chapter II
Part 200 Subpart D 200.319 Procurement Standards. 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 this section and §200.320. The non-Federal
entity must have written procedures for procurement transactions.
These procedures must ensure that all solicitations incorporate a clear and accurate description of the
technical requirements for the material, product, or service to be procured. Such description must not,
in competitive procurements, contain features which unduly restrict competition. The description may
include a statement of the qualitative nature of the material, product or service to be procured and,
when necessary, must set forth those minimum essential characteristics and standards to which it
must conform if it is to satisfy its intended use.
Noncompetitive procurements can only be awarded in accordance with §200.320(c). According to 2
CFR §200.320 Procurement Standards, there are specific circumstances in which noncompetitive
procurement can be used. Noncompetitive procurement can only be awarded if one or more of the
following circumstances apply:
1. The acquisition of property or services, the aggregate Dollar amount of which does not exceed the
micro-purchase threshold (see paragraph (a)(1) of this section);
2. The item is available only from a single source;
3. The public exigency or emergency for the requirement will not permit a delay resulting from
publicizing a competitive solicitation;
4. The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive
procurement in response to a written request from the non-Federal entity; or
5. After solicitation of a number of sources, competition is determined inadequate. Condition: During our testing over procurement, we determined that while the Museum does have an
established procurement policy in place, the Museum did not clearly document the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for
the contract price.
Cause: Management did not have effective internal controls in place to ensure that procurement
requirements were adequately documented and retained.
Effect or Potential Effect: Procurement records were insufficient to meet the requirements noted in
the Criteria section above, as well as the Museum's internal procurement policy.
Questioned Costs: None noted.
Context: We noted that items selected for testing did not document the rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Identification as a Repeat Finding, if Applicable: Not a repeat finding.
Recommendation: We recommend the Museum retain sufficient procurement documentation to meet
the requirements noted in the Criteria section above.
Finding 2024-004: Suspension and Debarment (Significant Deficiency)
Information on the Federal Program: 45.301 - Institute of Museum and Library Services
Criteria: Under 2 CFR §200.213, non-Federal entities are subject to the non-procurement debarment
and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These
regulations restrict awards, subawards, and contracts with certain parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities. The non-Federal entity must verify that the person with whom you intend to do business is
not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that
person; or (c) Adding a clause or condition to the covered transaction with that person.
Condition: During our testing over Suspension and Debarment, we determined that the Museum did
not perform screenings on the vendors selected for testing.Cause: The Museum does not have a formal internal policy with respect to screening vendors,
suppliers, contractors and employees in order to adhere to compliance over suspension and
debarment.
Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment
occurs) potential and current vendors, suppliers, contractors and employees increases the potential
that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the
United States Government.
Questioned Costs: None noted.
Context: We noted that vendors, suppliers, contractors and employees selected for testing did not
have a formally documented Suspension and Debarment check conducted prior to engagement.
Identification as a Repeat Finding, if Applicable: Not a repeat finding.
Recommendation: We recommend that management develop and implement a formal policy on
suspension and debarment. This policy should include a threshold for when vendors, suppliers,
contractors and employees should be screened. All screenings should be conducted prior to signing a
contract or issuing payment. We recommend that the Museum notify all employees of this policy and
ensure that it is enforced during the upcoming fiscal year.
Finding 2024-002: Reporting (Significant Deficiency)
Information on the Federal Program: 45.301 - Institute of Museum and Library Services
Criteria or Specific Requirement: As noted in 2 CFR §200.328 Monitoring and reporting program
performance (b)(1), “The non-Federal entity must submit performance reports at the interval required
by the Federal awarding agency”.
Condition: During the audit, we noted that the program reports selected for testing were not submitted
within the timeframe stipulated in the award agreement.
Cause: Management did not have effective internal controls in place to ensure that program reports
would be submitted timely and in line with requirements in the award agreement.
Effect or Potential Effect: Without established controls over reporting, there is a reasonable
possibility that the Museum would not detect noncompliance in the normal course of performing duties
and correct them in a timely manner.
Questioned Costs: None noted.
Context: 3 of the 3 program reports selected for testing were not submitted by the due date stipulated
in the award agreement.
Identification as a Repeat Finding, if Applicable: Not a repeat finding.
Recommendation: We recommend that management of the Museum ensure that all programmatic
reporting requirements are clearly communicated to program staff and managers. Controls should be
implemented to ensure that reports are prepared and submitted within a timely manner to the Federal
agency.
Finding 2024-003: Procurement (Significant Deficiency)
Information on the Federal Program: 45.301 - Institute of Museum and Library Services
Criteria: According to 2 CFR §200.303, the non-Federal entity must: (a) 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).
Additionally, according to 2 CFR §200.318 Procurement standards, the non-Federal entity must
maintain records sufficient to detail the history of procurement. These records will include, but are not
necessarily limited to, the following: Rationale for the method of procurement, selection of contract
type, contractor selection or rejection, and the basis for the contract price. Title 2, Subtitle A Chapter II
Part 200 Subpart D 200.319 Procurement Standards. 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 this section and §200.320. The non-Federal
entity must have written procedures for procurement transactions.
These procedures must ensure that all solicitations incorporate a clear and accurate description of the
technical requirements for the material, product, or service to be procured. Such description must not,
in competitive procurements, contain features which unduly restrict competition. The description may
include a statement of the qualitative nature of the material, product or service to be procured and,
when necessary, must set forth those minimum essential characteristics and standards to which it
must conform if it is to satisfy its intended use.
Noncompetitive procurements can only be awarded in accordance with §200.320(c). According to 2
CFR §200.320 Procurement Standards, there are specific circumstances in which noncompetitive
procurement can be used. Noncompetitive procurement can only be awarded if one or more of the
following circumstances apply:
1. The acquisition of property or services, the aggregate Dollar amount of which does not exceed the
micro-purchase threshold (see paragraph (a)(1) of this section);
2. The item is available only from a single source;
3. The public exigency or emergency for the requirement will not permit a delay resulting from
publicizing a competitive solicitation;
4. The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive
procurement in response to a written request from the non-Federal entity; or
5. After solicitation of a number of sources, competition is determined inadequate. Condition: During our testing over procurement, we determined that while the Museum does have an
established procurement policy in place, the Museum did not clearly document the rationale for the
method of procurement, selection of contract type, contractor selection or rejection, and the basis for
the contract price.
Cause: Management did not have effective internal controls in place to ensure that procurement
requirements were adequately documented and retained.
Effect or Potential Effect: Procurement records were insufficient to meet the requirements noted in
the Criteria section above, as well as the Museum's internal procurement policy.
Questioned Costs: None noted.
Context: We noted that items selected for testing did not document the rationale for the method of
procurement, selection of contract type, contractor selection or rejection, and the basis for the contract
price.
Identification as a Repeat Finding, if Applicable: Not a repeat finding.
Recommendation: We recommend the Museum retain sufficient procurement documentation to meet
the requirements noted in the Criteria section above.
Finding 2024-004: Suspension and Debarment (Significant Deficiency)
Information on the Federal Program: 45.301 - Institute of Museum and Library Services
Criteria: Under 2 CFR §200.213, non-Federal entities are subject to the non-procurement debarment
and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These
regulations restrict awards, subawards, and contracts with certain parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities. The non-Federal entity must verify that the person with whom you intend to do business is
not excluded or disqualified, by (a) Checking SAM Exclusions; or (b) Collecting a certification from that
person; or (c) Adding a clause or condition to the covered transaction with that person.
Condition: During our testing over Suspension and Debarment, we determined that the Museum did
not perform screenings on the vendors selected for testing.Cause: The Museum does not have a formal internal policy with respect to screening vendors,
suppliers, contractors and employees in order to adhere to compliance over suspension and
debarment.
Effect or Potential Effect: Failure to screen, in a timely manner (before contract date or payment
occurs) potential and current vendors, suppliers, contractors and employees increases the potential
that Federal funds be inadvertently provided to parties deemed to be suspended or disbarred by the
United States Government.
Questioned Costs: None noted.
Context: We noted that vendors, suppliers, contractors and employees selected for testing did not
have a formally documented Suspension and Debarment check conducted prior to engagement.
Identification as a Repeat Finding, if Applicable: Not a repeat finding.
Recommendation: We recommend that management develop and implement a formal policy on
suspension and debarment. This policy should include a threshold for when vendors, suppliers,
contractors and employees should be screened. All screenings should be conducted prior to signing a
contract or issuing payment. We recommend that the Museum notify all employees of this policy and
ensure that it is enforced during the upcoming fiscal year.