Finding: Per 2 CFR 200.303, the Council must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a ...
Finding: Per 2 CFR 200.303, the Council must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Corrective Actions Taken or Planned: Recently we implemented and communicated a revised Procurement policy that reinstates the requirement of 3 competitive bids if the requisition amount is over $10K. NSC will ensure reinforcement of this policy through multiple layers of review (Legal, Accounting and Executives). Although, the policy was recently reinstated NSC will ensure that it will abide to the policy as much as is possible for all purchases prior to November 1st. In order to facilitate and implement the new procurement policy, NSC will utilize ERP system AVID which helps create approval routings through automated workflows. Accounting, Legal and up to the VP level will ensure and review proper documentation. The CFO and COO will be the final line of review prior to ultimate approval for all purchases above the VP delegation level of authority. The following approvals are required for procurements for items up to: 15K by VP?s of business units 50K by CFO, 100K by COO, Over $100K by CEO. A thorough review of Federal grants will be performed and a new standard operating procedure created, to ensure that all federal ruled are properly being followed as part of the procurement policy. Finally, multiple training sessions and communications to all affected staff will be conducted in order to ensure future compliance at all levels. Anticipated completion date: October 27th 2022 Individual Responsible: Ron Hausner, CFO