Audit 390804

Criteria: Per Federal regulations for general procurement standards (2 CFR § 200.318 (i)), non‑Federal entities must maintain records sufficient to detail the history of the procurement process. These records will include but are not limited to the following: rationale for the method of procurement, selection or rejection, and the basis for the contract price. Condition: In our procurement testing for CSLFRF funding, the City was unable to provide evidence that demonstrates public notice was published according to (2 CFR § 200.320(b)) for the projects selected. Cause and Effect: Due to the City not conducting procurement for all CSLFRF expenditures through its projects, sufficient evidence was not available to demonstrate that full and open competition was provided to potential bidders, as required. Documentation supporting compliance with procurement requirements, including public notice and solicitation efforts, was not available. Recommendation: We recommend the City implement and enforce procurement policies that require formal solicitation of bids for applicable projects. Initiating a competitive bidding process helps ensure compliance with federal and state procurement standards, promotes transparency, and supports the selection of the most qualified and cost‑effective vendors. Management Response: Management concurs with the finding that procurement documentation for CSLFRF‑funded projects was insufficient to demonstrate compliance with federal procurement standards, including the requirement for public notice under 2 CFR § 200.320(b). The absence of complete records limited the City’s ability to show that full and open competition was provided. To address this issue, the City will revise and strengthen its procurement policies to require formal solicitation and complete documentation for all applicable projects. A centralized system for retaining procurement records will be implemented to ensure that evidence of public notice, solicitation efforts, bid evaluations, and contract award decisions is consistently maintained. Staff involved in procurement will receive training on federal requirements, and a pre‑award compliance checklist will be introduced to verify that all required documentation is in place before contracts are executed. Management will work with all departments involved in procurement to reinforce expectations, implement improved procedures, and ensure that required documentation is consistently retained.

Criteria: In order to comply with filing of reports with the Oklahoma State Auditor and Inspector (State Auditor), management needs to appropriately monitor the timing of the submission of the filing of the audit report within six months after the end of the fiscal year. Additionally, the Federal Audit Clearinghouse (FAC) submission should occur the earlier of nine months subsequent to year end or 30 days from report issuance. Condition: The City did not submit its audit report to the State Auditor prior to the deadline of six months after the end of the fiscal year ending December 31, 2024. Additionally, the City did not submit its audit report to the FAC within nine months from year ending December 31, 2024. Cause and Effect: A change in key personnel over the City’s financial reporting and a natural disaster which occurred after year end resulted in a delayed financial reporting closeout of fiscal year 2024. As a result, the City was not in compliance with its required deadline to provide the State Auditor and the FAC with its issued audit report within the established deadlines. Recommendation: We recommend the internal controls for reporting with the State Auditor and FAC be reviewed to ensure that future filings are completed within the established deadlines. Management response: Management acknowledges the finding regarding the delayed submission of the City’s audit report to both the Oklahoma State Auditor and Inspector and the Federal Audit Clearinghouse. We agree that the combination of turnover in key financial reporting positions and the impact of a natural disaster contributed to delays in completing the fiscal year 2024 financial close and subsequent filings. The City recognizes the importance of timely reporting to maintain compliance with state and federal requirements. Management is committed to strengthening internal controls, improving communication among departments, and ensuring that future audit submissions are completed within the required deadlines.