Federal Agency: U.S. Department of the Treasury
Federal Program Name: State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2619, 2024
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: January 1, 2024, through December 31, 2024.
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: Procurement policy should be in place to ensure compliance with program requirements as stated in: UG §200.318 General procurement standards, UG §200.319 Competition, §200.320 Methods of procurement to be followed, and §200.321 Contracting with small and minority businesses, women's business enterprises, and labor surplus area firms.
Condition: There is no procurement policy in place.
Questioned costs: None noted.
Context: The City does not have an adequate procurement policy
Cause: No policy was created as the City has not had a single audit in prior years.
Effect: Procurement could be out of compliance with program requirements.
Repeat Finding: No.
Recommendation: CLA recommends that the City implement a formal procurement policy.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2619, 2024
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: January 1, 2024, through December 31, 2024.
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The City should ensure Suspension & Debarment procedures are documented, followed and performed.
Condition: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Questioned costs: None noted.
Context: The City was unaware consultants also needed to be checked for suspension and debarment.
Cause: Procedures not formalized when updated and one vendor was not properly verified.
Effect: Lack of updated policies and suspension & debarment procedures being performed could lead to the vendor entering into a covered transaction with a suspended or debarred procedure or that incorrect procedures being performed.
Repeat Finding: No.
Recommendation: We recommend the City formalizes their suspension & debarment procedures in a policy and ensure they check suspension & debarment for all vendors prior to entering into a covered transaction.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2619, 2024
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: January 1, 2024, through December 31, 2024.
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The City should retain all procurement documentation.
Condition: 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.
Questioned costs: None noted.
Context: The City did not retain procurement documentation as an outside consultant handled the procurement process.
Cause: The City did not retain documentation.
Effect: Procurement could be out of compliance with program requirements.
Repeat Finding: No.
Recommendation: CLA recommends that the City implement a formal procurement policy.
Views of responsible officials: There is no disagreement with the audit finding.
SECTION IV – MINNESOTA LEGAL COMPLIANCE
Our audit did not disclose any matters required to be reported in accordance with Minnesota Legal Compliance Audit Guide for Counties, promulgated by the State Auditor.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2619, 2024
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: January 1, 2024, through December 31, 2024.
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: Procurement policy should be in place to ensure compliance with program requirements as stated in: UG §200.318 General procurement standards, UG §200.319 Competition, §200.320 Methods of procurement to be followed, and §200.321 Contracting with small and minority businesses, women's business enterprises, and labor surplus area firms.
Condition: There is no procurement policy in place.
Questioned costs: None noted.
Context: The City does not have an adequate procurement policy
Cause: No policy was created as the City has not had a single audit in prior years.
Effect: Procurement could be out of compliance with program requirements.
Repeat Finding: No.
Recommendation: CLA recommends that the City implement a formal procurement policy.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2619, 2024
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: January 1, 2024, through December 31, 2024.
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The City should ensure Suspension & Debarment procedures are documented, followed and performed.
Condition: When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Questioned costs: None noted.
Context: The City was unaware consultants also needed to be checked for suspension and debarment.
Cause: Procedures not formalized when updated and one vendor was not properly verified.
Effect: Lack of updated policies and suspension & debarment procedures being performed could lead to the vendor entering into a covered transaction with a suspended or debarred procedure or that incorrect procedures being performed.
Repeat Finding: No.
Recommendation: We recommend the City formalizes their suspension & debarment procedures in a policy and ensure they check suspension & debarment for all vendors prior to entering into a covered transaction.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2619, 2024
Pass-Through Agency: N/A
Pass-Through Number(s): N/A
Award Period: January 1, 2024, through December 31, 2024.
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The City should retain all procurement documentation.
Condition: 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.
Questioned costs: None noted.
Context: The City did not retain procurement documentation as an outside consultant handled the procurement process.
Cause: The City did not retain documentation.
Effect: Procurement could be out of compliance with program requirements.
Repeat Finding: No.
Recommendation: CLA recommends that the City implement a formal procurement policy.
Views of responsible officials: There is no disagreement with the audit finding.
SECTION IV – MINNESOTA LEGAL COMPLIANCE
Our audit did not disclose any matters required to be reported in accordance with Minnesota Legal Compliance Audit Guide for Counties, promulgated by the State Auditor.