U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-005 Procurement and Suspension and Debarment Criteria: The Uniform Guidance regulations (?200.320) require, among other things, that procurement for purchases of goods and services follow certain procedures related to obtaining and awarding of contracts based on sealed bid, competitive-, and noncompetitive proposals. Additionally, ?200.318(d) provides that written policies and procedures must document the avoidance of the acquisition of unnecessary or duplicative items. In addition, non-federal entities are prohibited from contracting with parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: The portion related to procurement is a repeated finding from 2019, 2020 and 2021. During our testing of purchases under the procurement regulations, for 2 out of 10 vendors (paid approximately $1.59 million out of the amount tested of $12.8 million) selected for testing, the System was unable to provide supporting documentation that these vendor services or supplies were procured in accordance with the standards in ?200.320. The universe (population) from which the items were selected was all vendor payments in 2022 over $10,000 consisting of 154 vendors paid approximately $22 million. Additionally, while the System does maintain written policies and procedures related to procurement standards, documentation addressing the acquisition of unnecessary or duplicative items was not present.Condition: During our testing of compliance with the suspension and debarment regulations, for 2 out of 10 vendors selected for testing (same vendors selected for procurement testing above), the System was unable to provide documentation of its conclusions that these vendor were not suspended or debarred. The universe (population) from which the items were selected were all vendor payments in 2022 over $25,000 consisting of 94 vendors paid approximately $21 million. Based on a review of SAM.gov, none of these vendors were suspended or debarred. Questioned Costs: Unknown. Cause: A material weakness exists in the internal controls over procurement and suspension and debarment. The System does not have adequate controls in place to ensure that appropriate supporting documentation is maintained for purchases made under the procurement standards to support the System?s consideration and/or conclusion for obtaining and awarding of contracts based on sealed bid, competitive, and noncompetitive proposals or its determination of whether the vendor is suspended or debarred. Additionally, written policies and procedures for procurement were not reviewed to ensure all requirements under these regulations were addressed. Effect: The System may not be receiving the overall lowest cost for services and supplies procured by the agency. Without ensuring documentation is maintained over whether a vendor is suspended or debarred, the System may enter into contracts with unauthorized parties. Recommendation: We recommend the System implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. Additionally, we recommend that the System enhance its written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies should include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. A review of all contracts to ensure the appropriate language exits regarding suspension and debarment regulations or the System should consider an annual review of SAM.gov for all vendors.View of Responsible Official: The Agency will implement internal controls to ensure that supporting documentation is maintained for the procurement of goods and services in accordance with ?200.320. The Agency will update our written policies and procedures to ensure that documentation is included regarding the avoidance of the acquisition of unnecessary or duplicative items. Documentation and policies will include procedures for the competitive bidding of bus parts on a quarterly basis and evidence that purchases are from these bid responses and from the lowest qualified vendor. Procurement will perform an annual review of SAM.gov for all vendors.
U.S. Department of Transportation FEDERAL TRANSIT CLUSTER 20.507 Federal Transit Formula Grant (applies to all grants) 20.526 Section 5339 Formula Apportionment 2022-006 Activities Allowed or Unallowed Allowable Costs/Cost Principles Criteria: Establishment of a payroll file enables accounting personnel to pay the employee without accessing employee confidential information which is maintained in a personnel file. Accounting and Finance personnel can keep payroll records in a secure location. Proper internal controls to ensure proper payment to employees would require that payroll files be updated with proper documentation to support wage rates paid to personnel. Condition: This is a repeat finding from 2021. During our testing of internal controls over payroll, we noted for 10 out of 65 individuals selected for testing, no documentation existed for the approval of the current rate of pay. We were able to verify the pay rates appeared appropriate through other audit procedures such as review of the positions and comparison of pay rates to prior year records. The population was all payroll. This is not a statistically valid sample. Questioned Costs: None. Cause: Turnover in key personnel in the human resources and finance departments resulted in the lack of documentation in payroll files.Effect: The System is unable to demonstrate that wages paid to all of its employees is appropriately approved. Recommendation: We recommend that the System adopt written policies and procedures to ensure that documentation of approved pay rates is maintained. View of Responsible Official: The Agency has contracted with a vendor to provide them with assistance in ensuring the system of record is properly set up to maintain and track all pay updates and changes.