Audit 403074

2025-001 PROCUREMENT, SUSPENSION AND DEBARMENT Grantors: U. S. Department of Justice U. S. Department of Health and Human Services Federal Program Names: Crime Victim Assistance Maternal, Infant and Early Childhood Home Visiting Grant FALN Numbers: 16.575 and 93.870 Pass-through Entities: CT Office of Victim Services CT Office of Early Childhood Criteria: When procuring property and services, entities must follow the procurement standards set out at 2 CFR sections 200.318-200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The procurement policy in place during the first part of fiscal 2025 was not updated to comply with the requirement of the Uniform Guidance as stated above, and did not specify a micro-purchase or small purchase threshold above which written quotes would be required, although this was addressed in January 2025. A formal written policy for ensuring vendors are not suspended or debarred was not included in the old policy and, although the new policy does include such language, no specific procedures were performed regarding the determination as to whether vendors were suspended or debarred. Questioned Costs: None. Effect: Certain purchases could be incurred at higher amounts than might have been the case had multiple written quotes been obtained prior to the transaction. However, all purchases tested appeared to be in the normal course of business and costs appeared reasonable. Our testing did not result in any questioned costs. Additionally, the potential existed that a vendor that could either be suspended or debarred could have unknowingly been utilized due to the existing process. Cause: The agency did not timely complete the process to update its policies and procedures to conform with the Uniform Guidance by the expiration of the extended implementation deadline cited in the Uniform Guidance. A new procurement policy was implemented during the fiscal year, however while the policy states that suspension and debarment of vendors will be addressed, no procedures were actually implemented and documented to ensure that new or existing vendors’ statuses were verified. Recommendation: Management should create and implement a procedure that ensures all vendors are checked for suspension and debarment on an ongoing basis to prevent any further noncompliance in this area. Additional training of relevant staff regarding the new policies and procedures should be considered, especially regarding retention of adequate documentation of bids, quotes, or other procedures including documentation of the checking of vendors against the suspension and debarment lists. Views of Responsible Officials: A new procurement procedure to ensure vendors are not suspended or debarred, was prepared and implemented effective in fiscal 2026. Relevant staff have been and continue to be trained appropriately regarding execution of related procedures to ensure all aspects are being properly performed.