Criteria: 2 CFR Part 200 requires that nonfederal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the specific award. Condition: During our testing of the County’s compliance with the procurement requirements for the Coronavirus State and Local Fiscal Recovery Funds, we noted that payments in the amount of $97,155 did not follow the County’s established procurement policy. For this purchase, which consisted of three separate items, the County obtained competitive bids from three (3) separate vendors and selected the vendor with the lowest cost quote. However, the County’s procurement policy requires that purchases in excess of $50,000 be competitively bid. The three (3) separate items comprising this purchase were initially viewed as separate and distinct, and, therefore, no competitive bids were advertised. Cause: The County’s internal controls over compliance were not sufficiently designed or operating effectively to ensure that staff responsible for contracting federally-funded goods and services adhered to the specific Federal requirements for competition, documentation, and proper procurement methods. Effect: The total known amount of expenditures related to this noncompliant procurement is $97,155, which are considered questioned costs. Additionally, the absence of adequate competition and documentation increases the risk that Federal funds were not used in the most economical and efficient manner. Recommendation: We recommend the County assess and potentially clarify its existing procurement policies to ensure that related purchases are subject to the County’s procurement policies, as applicable. Management's Response: The County Finance Department agrees with this finding and the audit recommendation. The County Procurement department is reviewing its policies and will adopt updates as required.