Audit 397672

Finding #SA2025-001: Compliance with Grant Procurement Requirements Assistance Listing Number: 16.922 Assistance Listing Title: Equitable Sharing Program Name of Federal Agency: Department of Justice Federal Award Identification Number: Not Applicable Criteria: Section VI.A.3 of the Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies requires that the City “Process all expenditures and payments in the same manner as appropriated funds, including procurement and payment transactions.” The 2025 OMB Compliance Supplement further clarifies that means the City is to follow its own procurement policies. Condition: We selected eight expenditure transactions for testing that included five vendors that we tested for compliance with the City’s procurement policies. Three of the vendor transactions complied with the City’s procurement policies. Although the two other vendor transactions were approved by the Police Chief in compliance with the City’s Equitable Sharing Program policy, they were not in compliance with the City’s purchasing policy. Since the purchases of supplies were each more than $10,000, but less than $25,000, the City’s purchasing policy requires the department to obtain at least three informal quotes, but quotes were not obtained for the two purchases. Effect: The City is not in compliance with the procurement requirements of the grant as well as its own purchasing policy. Cause: We understand that Police Department staff thought the Equitable Sharing Program policy of purchases being approved by the Police Chief satisfied the procurement requirements. Recommendation: The City should ensure that all purchases under the Equitable Sharing Program comply with the requirements of the City’s purchasing policy. If the City intends to use the Equitable Sharing Program policy for the program without reference to the City’s Purchasing and other applicable policies, the Equitable Sharing Program policy should be updated to ensure it includes all elements required by the Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies and the annual OMB Compliance Supplement including those for procurement. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.