Condition: ASP, a sub-recipient, did not retain documentation of submission of all required reports to the pass-through entity, the City of Johnson City. Criteria: The grant agreement with the City requires an annual report, a projected expenditures report, and four quarterly reports be submitted by ASP. Cause: ASP did not retain documentation of submission of all required reports and controls and procedures in place did not allow for timely detection and correction of this error. Effect: ASP could not show that all reports that were required of them per the grant agreement were submitted. Context: Several reports required by the grant agreement between ASP and the City of Johnson City were not retained or documented in a way that provides detail as to the form, timeliness, or content of the report submission. Questioned Costs: N/A Recommendation: ASP should document and retain evidence of submission of all required reports per the grant agreement, including copies of any reporting, support for timeliness of reporting, and any feedback from the pass-through entity on reporting. Additionally, ASP should review controls and procedures in place to ensure that there are policies to help aid with timely report completion, review, and submission. Repeat Finding: No. Management?s Response: ASP complied with and submitted required progress reports, proof of expenditures, and communication requests from the Community Development Block Grant administrators. Some of those reports were requested and accepted orally therefore producing minimal written record of their occurrence. ASP did receive a letter of affirmation by the CDBG Administrator of ASP's compliance. In the future, ASP will ensure written record of and tracking of all submitted reports.
Condition: ASP does not have written procurement policies that fully align with requirements in the Uniform Guidance. Criteria: In December 2018, the sections of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) covering procurement became effective after a three-year grace period on the implementation date. The Uniform Guidance requires entities to have written policies and procedures in place covering most types of procurement, as well as related matters such as conflicts of interest, avoidance of geographical preferences, bidding thresholds, required contract language, and others. Cause: ASP hasn?t been subject to the Uniform Guidance single audit requirements during recent fiscal years and while having various components of policies in places, has not adopted a complete policy. Effect: Procurement procedures may not be conducted in accordance with Uniform Guidance requirements. Context: Several Uniform Guidance procurement requirements were not noted in ASP?s procurement policy. Questioned Costs: N/A Recommendation: ASP should prepare a revised policy for procurement procedures to more closely align with Uniform Guidance requirements. Repeat Finding: No. Management?s Response: ASP had updated our written procurement policies and procedures to comply with the December 2018 Uniform Guidance. However, we will review and write a more detailed version of those policies to ensure complete and continuous compliance with the requirements in the Uniform Guidance.
Condition: ASP does not have written procurement policies that fully align with requirements in the Uniform Guidance. Criteria: In December 2018, the sections of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) covering procurement became effective after a three-year grace period on the implementation date. The Uniform Guidance requires entities to have written policies and procedures in place covering most types of procurement, as well as related matters such as conflicts of interest, avoidance of geographical preferences, bidding thresholds, required contract language, and others. Cause: ASP hasn?t been subject to the Uniform Guidance single audit requirements during recent fiscal years and while having various components of policies in places, has not adopted a complete policy. Effect: Procurement procedures may not be conducted in accordance with Uniform Guidance requirements. Context: Several Uniform Guidance procurement requirements were not noted in ASP?s procurement policy. Questioned Costs: N/A Recommendation: ASP should prepare a revised policy for procurement procedures to more closely align with Uniform Guidance requirements. Repeat Finding: No. Management?s Response: ASP had updated our written procurement policies and procedures to comply with the December 2018 Uniform Guidance. However, we will review and write a more detailed version of those policies to ensure complete and continuous compliance with the requirements in the Uniform Guidance.
Condition: ASP, a sub-recipient, did not retain documentation of submission of all required reports to the pass-through entity, the City of Johnson City. Criteria: The grant agreement with the City requires an annual report, a projected expenditures report, and four quarterly reports be submitted by ASP. Cause: ASP did not retain documentation of submission of all required reports and controls and procedures in place did not allow for timely detection and correction of this error. Effect: ASP could not show that all reports that were required of them per the grant agreement were submitted. Context: Several reports required by the grant agreement between ASP and the City of Johnson City were not retained or documented in a way that provides detail as to the form, timeliness, or content of the report submission. Questioned Costs: N/A Recommendation: ASP should document and retain evidence of submission of all required reports per the grant agreement, including copies of any reporting, support for timeliness of reporting, and any feedback from the pass-through entity on reporting. Additionally, ASP should review controls and procedures in place to ensure that there are policies to help aid with timely report completion, review, and submission. Repeat Finding: No. Management?s Response: ASP complied with and submitted required progress reports, proof of expenditures, and communication requests from the Community Development Block Grant administrators. Some of those reports were requested and accepted orally therefore producing minimal written record of their occurrence. ASP did receive a letter of affirmation by the CDBG Administrator of ASP's compliance. In the future, ASP will ensure written record of and tracking of all submitted reports.
Condition: ASP does not have written procurement policies that fully align with requirements in the Uniform Guidance. Criteria: In December 2018, the sections of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) covering procurement became effective after a three-year grace period on the implementation date. The Uniform Guidance requires entities to have written policies and procedures in place covering most types of procurement, as well as related matters such as conflicts of interest, avoidance of geographical preferences, bidding thresholds, required contract language, and others. Cause: ASP hasn?t been subject to the Uniform Guidance single audit requirements during recent fiscal years and while having various components of policies in places, has not adopted a complete policy. Effect: Procurement procedures may not be conducted in accordance with Uniform Guidance requirements. Context: Several Uniform Guidance procurement requirements were not noted in ASP?s procurement policy. Questioned Costs: N/A Recommendation: ASP should prepare a revised policy for procurement procedures to more closely align with Uniform Guidance requirements. Repeat Finding: No. Management?s Response: ASP had updated our written procurement policies and procedures to comply with the December 2018 Uniform Guidance. However, we will review and write a more detailed version of those policies to ensure complete and continuous compliance with the requirements in the Uniform Guidance.
Condition: ASP does not have written procurement policies that fully align with requirements in the Uniform Guidance. Criteria: In December 2018, the sections of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) covering procurement became effective after a three-year grace period on the implementation date. The Uniform Guidance requires entities to have written policies and procedures in place covering most types of procurement, as well as related matters such as conflicts of interest, avoidance of geographical preferences, bidding thresholds, required contract language, and others. Cause: ASP hasn?t been subject to the Uniform Guidance single audit requirements during recent fiscal years and while having various components of policies in places, has not adopted a complete policy. Effect: Procurement procedures may not be conducted in accordance with Uniform Guidance requirements. Context: Several Uniform Guidance procurement requirements were not noted in ASP?s procurement policy. Questioned Costs: N/A Recommendation: ASP should prepare a revised policy for procurement procedures to more closely align with Uniform Guidance requirements. Repeat Finding: No. Management?s Response: ASP had updated our written procurement policies and procedures to comply with the December 2018 Uniform Guidance. However, we will review and write a more detailed version of those policies to ensure complete and continuous compliance with the requirements in the Uniform Guidance.