Audit 367687

Federal Program 594 Environmental Infrastructure Assistance Program (AL #12.U01) Drinking Water State Revolving Fund (AL #66.468) Procurement, Suspension, and Debarment Criteria Per Uniform Guidance, “Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR section 200.318 through 200.326. They must use their own documented procurement procedures, which reflect appliable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Furthermore, “Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition During testing, we noted that the City does not have a procurement policy in place that follows Uniform Guidance. Also, we noted that the City entered into two covered transactions with vendors who were not reviewed for suspension and debarment before entering into these transactions. Questioned Costs None. Context The City does not have a procurement policy that follows Uniform Guidance. Also, we tested two vendors who were not reviewed for suspension and debarment from a population of two. Cause Management oversight. Effect The City is not in compliance with Uniform Guidance. Also, there is an increased risk of the City entering into a covered transaction with an entity that is suspended or debarred from receiving federal funds. Repeat Finding Yes. Prior audit finding 2023-005. Recommendation The City should implement a written procurement policy that follows Uniform Guidance. Furthermore, vendors should be reviewed for suspension and debarment before entering into a covered transaction. View of Responsible Officials The City agrees with the recommendation.

Federal Program 594 Environmental Infrastructure Assistance Program (AL #12.U01) Drinking Water State Revolving Fund (AL #66.468) Procurement, Suspension, and Debarment Criteria Per Uniform Guidance, “Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR section 200.318 through 200.326. They must use their own documented procurement procedures, which reflect appliable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Furthermore, “Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition During testing, we noted that the City does not have a procurement policy in place that follows Uniform Guidance. Also, we noted that the City entered into two covered transactions with vendors who were not reviewed for suspension and debarment before entering into these transactions. Questioned Costs None. Context The City does not have a procurement policy that follows Uniform Guidance. Also, we tested two vendors who were not reviewed for suspension and debarment from a population of two. Cause Management oversight. Effect The City is not in compliance with Uniform Guidance. Also, there is an increased risk of the City entering into a covered transaction with an entity that is suspended or debarred from receiving federal funds. Repeat Finding Yes. Prior audit finding 2023-005. Recommendation The City should implement a written procurement policy that follows Uniform Guidance. Furthermore, vendors should be reviewed for suspension and debarment before entering into a covered transaction. View of Responsible Officials The City agrees with the recommendation.

Federal Program 594 Environmental Infrastructure Assistance Program (AL #12.U01) Cash Management Criteria A system of internal controls requires all requests for reimbursements to be reviewed and approved before submission. Condition During testing, we noted one request for reimbursement report that was not properly signed off on, per City procedures. Questioned Costs None. Context In a population of 6 requests for reimbursement reports submitted, we selected 1 to test. We noted that one of the reports tested was not signed off on per City procedures. Cause Management oversight. Effect There is an increased risk of the City submitting an inaccurate request for reimbursement. Repeat Finding Yes. Prior audit finding 2023-006. Recommendation The City should follow their procedures for signing off on all requests for reimbursement reports before submitting the federal reimbursement. View of Responsible Officials The City agrees with the recommendation and will implement December 1, 2025.