Audit 38166

Identification of federal program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Department of the Treasury Criteria or specific requirement: 21.027 Part 4 Compliance Supplement: Procurement - Recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined in sections 602(c) and 603(c) of the Act and Treasury?s Interim Final Rule. As such, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. All other entities under the program, including subrecipients of a state, must follow the procurement standards in 2 CFR 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR 200.320. Uniform Guidance 2 C.F.R 200.318 through 2 C.F.R. 200.327 200.318(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.200.318(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not 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. Condition: It was noted during the audit of fiscal year 2022 that although Skagway Traditional Council (STC) has documented procurement policies consistent with Uniform Guidance. STC did not maintain evidence that it followed its own documented procurement policy for procurements greater than the micro-purchase threshold. Cause: STC does not have an administrative process to ensure that the procurement documentation supporting purchases greater than the micro-purchase threshold are maintained in accordance with STCs procurement policies. Effect or potential effect: STC is out of compliance with Uniform Guidance procurement standards in fiscal year 2022. Questioned Costs: None. Context: For this program, four procurements were greater than STC?s micro-purchase threshold and all four were tested against STC?s procurement policy, of those four, none of them had documentation supporting STC following STC?s procurement policies. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of STC?s internal control structure over compliance with Uniform Guidance, that STC prepare a checklist, reflective of STC?s approved procurement policies, that must be completed before procurements can be awarded and all documents supporting that checklist be filled together. Views of Responsible Officials: See Corrective Action Plan

Identification of federal program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Department of the Treasury Criteria or specific requirement: 21.027 Part 4 Compliance Supplement: Procurement - Recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined in sections 602(c) and 603(c) of the Act and Treasury?s Interim Final Rule. As such, recipients are expected to have procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. All other entities under the program, including subrecipients of a state, must follow the procurement standards in 2 CFR 200.318 through 200.327, including ensuring that the procurement method used for the contracts are appropriate based on the dollar amount and conditions specified in 2 CFR 200.320. Uniform Guidance 2 C.F.R 200.318 through 2 C.F.R. 200.327 200.318(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327.200.318(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not 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. Condition: It was noted during the audit of fiscal year 2022 that although Skagway Traditional Council (STC) has documented procurement policies consistent with Uniform Guidance. STC did not maintain evidence that it followed its own documented procurement policy for procurements greater than the micro-purchase threshold. Cause: STC does not have an administrative process to ensure that the procurement documentation supporting purchases greater than the micro-purchase threshold are maintained in accordance with STCs procurement policies. Effect or potential effect: STC is out of compliance with Uniform Guidance procurement standards in fiscal year 2022. Questioned Costs: None. Context: For this program, four procurements were greater than STC?s micro-purchase threshold and all four were tested against STC?s procurement policy, of those four, none of them had documentation supporting STC following STC?s procurement policies. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of STC?s internal control structure over compliance with Uniform Guidance, that STC prepare a checklist, reflective of STC?s approved procurement policies, that must be completed before procurements can be awarded and all documents supporting that checklist be filled together. Views of Responsible Officials: See Corrective Action Plan