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Management Response #2024-003: Previously, the Corporation faced challenges in effectively monitoring and documenting grant activity due to limited formal processes. Documentation of policies and procedures was insufficient, and supporting materials were not stored in a centralized location, making ...
Management Response #2024-003: Previously, the Corporation faced challenges in effectively monitoring and documenting grant activity due to limited formal processes. Documentation of policies and procedures was insufficient, and supporting materials were not stored in a centralized location, making information retrieval difficult. Since then, processes have improved, with enhanced documentation practices and better organization of grant-related records to support more efficient oversight and compliance. Corrective Action Plan: The Corporation has implemented the following corrective measures: • The Corporation established comprehensive, formal policies and procedures that document the current compliance practices. These procedures have been disseminated across the organization and incorporated into training programs to ensure all employees are aligned with the updated standards. • A procedure enhancement has been implemented in the procurement process, which requires the procurement manager to obtain three bids prior to the creation of certain purchase orders. This ensures competitive bidding and transparency in vendor selection. • Once a vendor is selected, the procurement manager will forward the vendor’s details to the compliance department. The compliance team will then verify the vendor's debarment status and federal eligibility to ensure compliance with all regulatory requirements. • A central repository platform has been created to store all vendor bids, price analyses, and related procurement documentation. This ensures that all relevant information is easily accessible and properly organized. • All accounts payable invoices designated for grant funding are now routed for prior approval to the respective grant program manager via the WorkPlace software before any payments are processed. This ensures proper oversight and alignment with grant requirements. These corrective actions aim to strengthen compliance, improve document management, and streamline oversight processes to prevent future issues related to grant monitoring and procurement. Management expects to be completed by December 31, 2026. Responsible Party: Tamara Barnes, CFO
Corrective Action Plan The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure tha...
Corrective Action Plan The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure that they are in compliance with Uniform Guidance. Individual(s) Responsible Sherry Bradley Completion Date Discussion is ongoing regarding the plan; it will be implemented by the end of 2025.
Finding 2024-002 Drinking Water State Revolving Fund - Procurement Contact Person Responsible for Corrective Action: JoAnn Collins/Clerk Treasurer Contact Phone Number and Email Address: 574-653-2112 kewanna@fourway.net Views of Responsible Officials: We concur with the finding Description of Correc...
Finding 2024-002 Drinking Water State Revolving Fund - Procurement Contact Person Responsible for Corrective Action: JoAnn Collins/Clerk Treasurer Contact Phone Number and Email Address: 574-653-2112 kewanna@fourway.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We will update our procurement policy and implement a system of internal controls to ensure a purchasing policy is in place and quotes are obtained for small purchases. Anticipated Completion Date: A policy and internal controls will be in place by January 1, 2026
FINDING 2024-003 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk-Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsi...
FINDING 2024-003 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk-Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31,2025
Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texa...
Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Additionally, Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Three of the four procurements noted as findings were, in fact, sole source procurements but lacked timely documentation of sole source rationale. Corrective Action Plan: Texas Biomed made a change in management over the procurement function and hired an experienced and knowledgeable Assistant Director of Supply Chain Management on September 15, 2025 to oversee procurement and ensure compliance with the necessary requirements. To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed will introduce a Purchasing Compliance Program. This program will include training and oversight procedures for the purchasing program. The training will include: new hire training, ongoing quarterly purchasing training for end users and purchasing staff. The purchasing team will maintain training documents and ensure new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures will be performed by the Assistant Director of Supply Chain Management and shall include auditing purchase orders over the micro-purchase threshold to ensure proper documentation is present. The Assistant Director of Supply Chain Management will also lead efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training October 2025 • Quarterly training session January 2026 • Oversight procedures developed November 2025 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: October 31, 2025
View Audit 368866 Questioned Costs: $1
FINDING 2024-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Timothy Detrick – Clerk-Treasurer Contact Phone Number and Email Address: treasurer@townoffrankton.in.gov Views of Res...
FINDING 2024-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Timothy Detrick – Clerk-Treasurer Contact Phone Number and Email Address: treasurer@townoffrankton.in.gov Views of Responsible Officials: Concur with the finding Description of Corrective Action Plan: I’ve already spoken with our Council President regarding the creation of an ordinance to establish a formal Procurement Policy, that mimics state law that’s already established. This ordinance will ensure that all new contracts entered into by the Town comply with Build America, Buy America (BABA) requirements. The ordinance will also ensure that the Town verifies both current and prospective vendors through the SAM.gov website to confirm their eligibility to receive federal funding. The ordinance will have in it that BABA must be follow and the town will verify that the contract is in good standing with the state but checking the SAM.gov website. Once check an affidavit will be made stating that that are in good standing, and signed by the council president and Clerk-Treasurer. Anticipated Completion Date: End of 2025 Date December 31st, 2025 INDIANA STATE
We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the fed...
We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Health System is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Health System will create a procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. Contact Person: Daniel Cooper, Vice President of Finance and Accounting Expected Completion Date: December 31, 2025
View Audit 367999 Questioned Costs: $1
FINDING 2024-002 Material Weakness-Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Brittany Couse Contact Phone Number: 765-677-2014 Views of Responsible Official: Agree with finding Description of Corrective Action Plan: The Clerk Treasurer's Office will continu...
FINDING 2024-002 Material Weakness-Procurement, Suspension, Debarment Contact Person Responsible for Corrective Action: Brittany Couse Contact Phone Number: 765-677-2014 Views of Responsible Official: Agree with finding Description of Corrective Action Plan: The Clerk Treasurer's Office will continue to check the System for Awards Management quarterly to verify any contractor is not debarred. Further, the office will now check for contracts that exceed the $25,000 threshold that require such inquiry. Anticipated Completion Date: Immediate
FINDING 2024-003 Finding Subject: Highway Planning and Construction - Procurement Contact Person Responsible for Corrective Action: Chance Bender, Highway Superintendent Contact Phone Number and Email Address: (812) 338-2162 / chancebender@crawfordcounty.in.gov Views of Responsible Officials: We con...
FINDING 2024-003 Finding Subject: Highway Planning and Construction - Procurement Contact Person Responsible for Corrective Action: Chance Bender, Highway Superintendent Contact Phone Number and Email Address: (812) 338-2162 / chancebender@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings of this report. Description of Corrective Action Plan: The County Highway Department has implemented a new filing system to help ensure that audit documentation is being maintained for all federal requirements. The County will maintain documentation of all bids and Letter of Interests (LOIs) received from vendors for each project for review. These files are maintained in their own folder with the DES# and project description on the outside. The County will also maintain documentation of the LPA Selection Review Checklist for each project for review. The County Highway Superintendent is responsible for maintaining all the files and the administrator will review/sign the checklist to ensure all the files are properly maintained. In addition, the County is currently working with the County's attorney to develop a procurement policy that includes federal regulations. Anticipated Completion Date: September 2025
FINDING 2024-004: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.c...
FINDING 2024-004: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The town attorney will draft a standard contract that will apply to any contractors that are paid $25,000.00 or more from federal funds, prior to entering a covered transaction ensuring that their respective contractor is not suspended or debarred. The council president will review and sign the contract ensuring the suspension and debarment clause is included in all respective contracts. The town has put controls and procedures in place to ensure timely documentation of suspension and debarment checks in regard to federal awards. For purchases procured outside of a contractual agreement, the town will require all vendors to self certify prior to entering into a transaction. The town will implement a procurement policy that conforms to the current requirements of CFR 200.318 for micro-purchases, under $10,000.00, the disbursing officer will only require board approval. For small purchases, between $10,000.00 and $150,000.00, three quotes must be obtained and a contract awarded. For purchases that exceed the simplified acquisition threshold, the town must allow for full and open competition in the form of a sealed bid process and awarding a contract. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.
Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFle...
Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025
Condition: The Organization did not maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance, for procurement transactions under a federal award or subaward. The Organization also did not comply with 2 CFR 200.318 (h) and 200.2...
Condition: The Organization did not maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance, for procurement transactions under a federal award or subaward. The Organization also did not comply with 2 CFR 200.318 (h) and 200.214 of the Uniform Guidance including verifying that vendors for covered transactions are not debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. There were two vendors with covered transactions charged to the major program. The vendors were not debarred, suspended, or otherwise excluded. However, the Organization did not perform and document the required verification. Recommendation: The Organization should draft and maintain documented procedures, consistent with the standards identified in 2 CFR 200.317 through 200.327 of the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.
FINDING 2024-002 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Neal McKee Contact Phone Number and Email Address: 765-648- 6429 nmckee@cityofanderson.com Views of Responsible Official...
FINDING 2024-002 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Neal McKee Contact Phone Number and Email Address: 765-648- 6429 nmckee@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has a longstanding contractual relationship with an engineering firm with extensive knowledge of the City’s water department. The city has put controls and procedures in place to ensure services are bid where federal awards are involved and the dollar amount of such services is expected to exceed the simplified acquisition threshold. The City will review its procurement policy and amend where necessary to conform to the current requirements of CFR 200.318. The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. Anticipated Completion Date: January 1, 2026
FINDING 2024-001 Finding Subject: Department of Transportation Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Brad King Contact Phone Number and Email Address: 765-648-6171 bking@cityofanderson.com Views of Responsible Officials: “We concur with the findin...
FINDING 2024-001 Finding Subject: Department of Transportation Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Brad King Contact Phone Number and Email Address: 765-648-6171 bking@cityofanderson.com Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The City has not contracted with suspended or debarred parties. The City has put controls and procedures in place to ensure timely documentation of suspension and debarment checks related to its federal awards. The City has implemented procedures to ensure the proper documentation of quotes taken where applicable. Anticipated Completion Date: September 1, 2025
Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Chief Information Officer Federal Financial Assistance Listing #21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: Our auditors identified the following during their testing of the fed...
Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Chief Information Officer Federal Financial Assistance Listing #21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: Our auditors identified the following during their testing of the federal program: • One instance where the Cooperative followed a bid process, however, the documentation was not retained to support the selection. Additionally, the contract with the vendor was missing required contract provisions in accordance with Uniform Guidance. • Two instances where the Cooperative did not follow the procurement process as detailed in the procurement policy and did not have any formal documentation or contract in place with the vendor. • Three instances where the Cooperative entered into a contract with a vendor over $25,000 and there was no review performed to ensure the vendor was not suspended or debarred. Corrective Action Plan: We plan to review our procurement policy with all parties that may enter into contracts for the cooperative to be sure the policy reflects our needs and that procedures are being followed. We will also implement a review process where management signs off on bid selection documentation, including verification that vendors are not suspended or debarred. Responsible Individuals: Hollee McCormick, General Manager and Jason Troendle, Director of Operations and Engineering Anticipated Completion Date: November 2025
Management’s Response: The Association will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.
Management’s Response: The Association will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.
View Audit 366950 Questioned Costs: $1
Corrective action plan: Management believes that the procurement process has improved considerably. Managers are following the procurement policy by making price comparisons and submitting quotes when required. Approvals for larger purchases are obtained by Resolution from Council. The Finance Manag...
Corrective action plan: Management believes that the procurement process has improved considerably. Managers are following the procurement policy by making price comparisons and submitting quotes when required. Approvals for larger purchases are obtained by Resolution from Council. The Finance Manager and the Accounts Payable Clerk monitor the documents submitted with purchase requests to ensure that the required documents have been submitted. Management believes that it is an isolated instance where a transaction lacked procurement documentation. Personnel responsible for corrective action: Lisa Donham (Finance Manager), Deidre Moyle (Accounts Payable), and Program Managers. Estimated corrective action completion date: December 31, 2025
Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, reporting and proper spending of all grant awards, including creating a capital outlay sub accoun...
Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, reporting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.
FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Dana Gault, Controller Contact Phone Number and Email Address: 765-382-3762 dgault@cityofmarion.in.gov Views of Responsible Offi...
FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Dana Gault, Controller Contact Phone Number and Email Address: 765-382-3762 dgault@cityofmarion.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The City Controller's office will provide instruction for all departments on retrieving letters from their vendors. This training is crucial for ensuring compliance with Suspension & Debarment regulations and establishing a robust system of internal controls for federal funds. Anticipated Completion Date: December 31, 2025
We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the fed...
We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.
View Audit 366228 Questioned Costs: $1
We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the fed...
We agree with the finding that internal controls were not sufficient to maintain compliance with federal procurement standards under Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.318 to 200.327 for a non-federal entity. However, the funds were expended for the intended purpose of the federal award. The Company is committed to implementing internal controls to ensure procurement related to federal awards follow 2 CFR section 200.318 to 200.327. The Company will update the procurement policy to ensure it complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest, governing the actions of its employees who select, award and administer procurement contracts. This policy will include procedures to ensure proper procurement for small purchases to ensure sufficient price quotations are obtained from the required number of qualified sources, proper sealed bids or proposals are obtained through public advertising, an appropriate cost or price analysis is performed for procurement actions exceeding the simplified acquisition threshold, documentation is retained, and proper oversight is exercised to demonstrate compliance with 2 CFR section 200.318 through 200.327. While the Company did not perform a check of each vendor against the SAM Exclusions prior to selecting a vendor, the Company has procedures in place to ensure the vendors are approved by Corporate purchasing and in good standing, which limits the risk of conflict of interest between employees and vendors, and contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with were not included on the SAM Exclusions listing. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: The procurement policy will be updated by September 30, 2025, and training will be provided to all employees who are relevant to the procurement process of federal contracts by December 31, 2025.
View Audit 366228 Questioned Costs: $1
Finding 575812 (2024-005)
Significant Deficiency 2024
Finding 2024-005 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Nate Moore, Finance Director Corrective Action: The Finance Department will regularly ensure that the procurement policy for the City is followed, and will be sure that it is reviewed often ...
Finding 2024-005 – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Nate Moore, Finance Director Corrective Action: The Finance Department will regularly ensure that the procurement policy for the City is followed, and will be sure that it is reviewed often to be sure that no modifications or adjustments need to be made. Anticipated Completion Date: June 30, 2026
Written procedures and conflict of interest policies in accordance with the Uniform Guidance will be established and implemented during the year ended June 30, 2026.
Written procedures and conflict of interest policies in accordance with the Uniform Guidance will be established and implemented during the year ended June 30, 2026.
2024-002 Finding Subject: COVID 19: Coronavirus State and Local Fiscal Recovery Funds - IFA Grant - White Ditch– Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Vie...
2024-002 Finding Subject: COVID 19: Coronavirus State and Local Fiscal Recovery Funds - IFA Grant - White Ditch– Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources. Description of Corrective Action Plan: All purchases need to be made in accordance with the Sanitary District of Michigan City Purchasing Policy. All contracts will be supported by a written and signed contract document per Section 9.0 of the Sanitary District of Michigan City Purchasing Policy. Suspension and Debarment 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (b) Formal Procurement Methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: . . . (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. . . . (2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Description of Corrective Action Plan For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025
FINDING 2024-001 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible...
FINDING 2024-001 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Procurement Federal regula􀆟ons allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisi􀆟on threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restric􀆟ve threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. Micro-purchases are typically for those purchases $10,000 or under, and small purchase procedures are for those purchases above the micro-purchase threshold, but below the simplified acquisi􀆟on threshold. Micro-purchases may be awarded without solici􀆟ng compe􀆟􀆟ve price rate quota􀆟ons. If small purchase procedures are used, then price or rate quota􀆟ons must be obtained from an adequate number of qualified sources Description of Corrective Action Plan: All purchases need to be made in accordance with the City of Michigan City Purchasing Policy. Purchases made under the Special Purchase provision (I.C.5-22-10-1) will abide by section 7.4 of the Michigan City Purchasing Policy. This section describes the required record keeping. Suspension and Debarment Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.320 states in part: (a) "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases– (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . Description of Corrective Action Plan: For all federally funded contracts exceeding $25,000, the Vendor will submit a statement indicating they were not suspended or debarred. For purchases not requiring a contract, the City Controller’s office will check the Excluded Parties List System prior to payment to the vendor. Anticipated Completion Date: 08/06/2025 INDIANA STATE
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