Audit 369055

Finding 2024-002 Material weakness in internal controls over procurement and material noncompliance related to procurement compliance requirements. Federal Agency: U.S. Department of Treasury Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Awards Number: SLFRP0152 Award Period: 1/1/2024 – 12/31/2025 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a non-Federal entity that has expended Federal awards to have written policies to its federal grants for procurement and that the history of each procurement is documented in accordance with 2 CFR section 200.318 to 200.320. Further, the regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Condition/Context During our testing, for three out of three procurement transactions tested in excess of the micro purchase threshold, the Organization did not maintain documentation sufficient to detail the history of the procurement transaction. The Organization did not maintain contemporaneous documentation identifying the procurement method, contract type selection, contract selection, basis of contract price, and consideration of vendor suspension and debarment. For one selection over the simplified acquisition threshold, the Organization received three proposals based upon a request for proposal process. For two selections above the micro-purchase threshold there was insufficient document to determine if price or rate quotations were obtained from an adequate number of qualified sources and no noncompetitive proposal process was documented in accordance with the Organizations procurement policy. Effect/Potential Effect Procurements were entered into that did not meet the minimum Uniform Guidance procurement standards. Questioned Costs N/A Repeat Finding Not applicable Recommendation We recommend that the Organization maintain records to support that any procurement entered into with federal funds was done so in accordance with its policies and procedures for procuring goods and services with the proceeds of a federal award. We further recommend that a control is implemented to ensure that the organization does not contract with parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Views of Responsible Officials Management agrees with the finding and has provided the corrective action plan following the Single Audit Report.