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Management's Response: 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...
Management's Response: 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. Until it is written, procurement standards will be reviewed and followed. Completion Date: Discussion is ongoing regarding the plan.
Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h). Th...
Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h). The Organization concurs with the prior year (2024-003) and current year renumbered recommendation (2025-003),and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Financial Policies – May 2025. Completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Initiated use of MTPF, and process implementation of Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal. C. HRSA Policies – July 2025. Developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. Informed the Board about the progress of the Organization’s policy framework, including the above policies. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work by the Organization: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the application of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). E. Updated procurement processes for emergency disaster recovery and support of community needs, including MTF documentation. Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date Finding No. 2025-003: Procurement Policies Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.
Views of Responsible Officials: Management acknowledges the finding and agrees with the recommendation. RoboNation recognizes the importance of maintaining complete procurement records for federally funded transactions, including documentation of vendor selection, procurement method, basis for price...
Views of Responsible Officials: Management acknowledges the finding and agrees with the recommendation. RoboNation recognizes the importance of maintaining complete procurement records for federally funded transactions, including documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and suspension/debarment verification. Once RoboNation was made aware of the deficiency during the 2023 audit, action was immediately taken and SAM.gov checks were completed in 2025 for all applicable vendors, not only new vendors. Management will further strengthen its procurement and suspension/debarment procedures by implementing a formal checklist requiring documentation of vendor selection, procurement method, basis for price, sole-source justification when applicable, and SAM.gov screening prior to contract execution or payment. Management will also ensure that supporting documentation is retained in the applicable procurement files and will provide comprehensive training and continued guidance to staff involved in Federally funded procurement to support consistent application of these procedures.
Before reviewing and updating it Fiscal Policies, including its purchasing and procurement policies, All Nations Finance Director and CEO will ensure that finance staff, the Audit and Finance Committee, and its accounting partner know how to adhere to and have a thorough understanding of the importa...
Before reviewing and updating it Fiscal Policies, including its purchasing and procurement policies, All Nations Finance Director and CEO will ensure that finance staff, the Audit and Finance Committee, and its accounting partner know how to adhere to and have a thorough understanding of the importance of complying with its purchasing and procurement policies.
Historic South acknowledges this finding is the same as reported in 2024. Although the corrective actions identified in the prior year’s audit were implemented, they were not fully in place during most of the period covered by the current audit. As a result, the transactions tested during the 2025 a...
Historic South acknowledges this finding is the same as reported in 2024. Although the corrective actions identified in the prior year’s audit were implemented, they were not fully in place during most of the period covered by the current audit. As a result, the transactions tested during the 2025 audit occurred before the corrective measures became effective. Corrective measures implemented include policies and procedures designed to strengthen its procurement and contracting processes. These include: 1. Requiring the solicitation of multiple bids for all construction work in excess of $10,000 2. Establishing criteria for awarding all construction work 3. Implementing formal contracting processes for all construction work Management believes these corrective actions address the deficiencies identified and expects them to be fully effective for construction activities occurring after implementation.
Finding 1229057 (2025-001)
Material Weakness 2025
Avivo
MN
Emergency Solutions Grant – Assistance Listing No. 14.231 Recommendation: We recommend that management implement formal procurement policies requiring periodic reassessment of vendors used in federally funded programs, particularly when new grant awards are received or grant periods change. This sho...
Emergency Solutions Grant – Assistance Listing No. 14.231 Recommendation: We recommend that management implement formal procurement policies requiring periodic reassessment of vendors used in federally funded programs, particularly when new grant awards are received or grant periods change. This should include evaluating whether the original procurement method remains appropriate, performing updated cost or price analyses as necessary, and conducting and documenting periodic suspension and debarment checks (e.g., SAM verification). Additionally, management should establish oversight controls to ensure procurement compliance and vendor eligibility are maintained throughout the lifecycle of vendor relationships in accordance with 2 CFR §200.318–200.320 and §200.214. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Avivo is in the process of updating its procurement policy and processes to include annual reviews of ongoing vendor contracts that will assess the appropriateness of the original procurement conditions and determine if updates or new analyses are required. Reviews will be signed off by the staff with contracting authority at the time of review; and if warranted, the appropriate staff will undertake new cost analyses, complete the documentation, and save in a shared repository that relevant departments will have access to. Program leadership is working with the appropriate administrative departments to develop the necessary processes for periodic review and the collection/storage of documentation around the periodic review process. The Accounting department has added a system-wide debarment check of all active vendors in the 3rd quarter of each year and will add any new vendors to this schedule regardless of when they were originally added to the vendor payment system. This ensures that all vendors are re-checked for debarment and suspension at minimum of one time annually. Name(s) of the contact person(s) responsible for corrective action: Kelly Matter Planned completion date for corrective action plan: 12/31/2026
Management concurs that a formal written procurement policy was not in place during the FY2025 audit period. Procurement activities were governed by established operational practices during FY2025, and a formal Procurement & Contract Administration Policy was adopted and implemented in March 2026. T...
Management concurs that a formal written procurement policy was not in place during the FY2025 audit period. Procurement activities were governed by established operational practices during FY2025, and a formal Procurement & Contract Administration Policy was adopted and implemented in March 2026. The policy establishes procurement methods, approval requirements, documentation standards, conflict-of-interest requirements, and procedures for noncompetitive procurements. Anticipated Completion Date: March 2026. Responsible Contact Person: Michael Quan, Director of Finance & Operations.
BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to e...
BGCPR agrees with the deficiency identified, mostly attributable to employee turnover within the Finance Division. As a result of this, during fiscal year 2026-2027 BGCPR will implement procedures to ensure proper procurement process including the following: a. Review the procurement check list to ensure that all required documentation is included within and ensure revision before a purchase order is issued to the vendor. b. Training to the personnel to guarantee that policy and procedures are implemented as required. c. Enforce standardized procedures to ensure that all approvals are consistently documented and maintained in accordance with policy or grant requirements. Contact Person: Purchase and procurement personnel Carlos Rivera Team: Finance Team Anticipated Completion Date: September 30, 2026
Management acknowledges that procurement documentation was not consistently maintained during the audit period. Because the FY2024 audit was completed after the FY2025 fiscal year had ended, management did not have an opportunity to implement the prior-year corrective actions in time to affect the F...
Management acknowledges that procurement documentation was not consistently maintained during the audit period. Because the FY2024 audit was completed after the FY2025 fiscal year had ended, management did not have an opportunity to implement the prior-year corrective actions in time to affect the FY2025 audit period. Since the audit period, the Organization has strengthened procurement and compliance oversight by elevating the Director of Programs position to Vice President of Programs in September 2025, launching the Compliance and Risk Management Committee in FY2026, and creating a Compliance & Evaluation Manager position with an anticipated start date in August 2026. Fiscal and program leadership have substantially revised the procurement policy and are developing related procedures and standardized documentation requirements. The policy and procedures will be reviewed by the Compliance and Risk Management Committee in early FY2027 before being submitted for Board approval. The revised materials address competitive quotations and bids, vendor selection, price reasonableness, noncompetitive procurement justifications, conflict-of-interest requirements, debarment verification, and documentation of the procurement history. The FY2027 budget includes 2 CFR Part 200 training for Fiscal, Programs, and Grants staff. Blackbaud Financial Edge, scheduled to go live in FY2027, will further support approval workflows, transaction tracking, role-based access, and document retention. Management is committed to achieving full compliance with Uniform Guidance procurement requirements. Actions Taken • Elevated the Director of Programs position to Vice President of Programs in September 2025. • Launched the Compliance and Risk Management Committee in FY2026. • Created a Compliance & Evaluation Manager position, with an anticipated start date in August 2026. • Strengthened supervisory review and reinforced procurement documentation expectations. • Substantially revised the procurement policy and began developing standardized procedures and documentation requirements. • Scheduled Compliance and Risk Management Committee review of the revised policy and procedures for the fall of 2026. • Included 2 CFR Part 200 training for Fiscal, Programs, and Grants staff in the FY2027 budget. • Initiated implementation of Blackbaud Financial Edge; planned go-live for October 2026.
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 implemented the procurement policy it created on September 30, 2025, in response to prior audit findings 2024-001 and 2024-003, which occurred after the end of the federal award year for this program, that addresses this finding. This procurement policy complies with the requirements of 2 CFR section 200.318 through 200.327, that includes the written standards of conduct covering conflicts of interest and governs the actions of its employees who select, award and administer procurement contracts. This policy includes 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 in accordance 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 limits contracting with a vendor who is suspended or debarred from federal related contracting. Further, the Company confirmed the vendors that were contracted with related to this finding were not included on the SAM Exclusions listing. The Company has now filed the Notice of Federal Interest (“NFI”), and provided the NFI to the appropriate HRSA Grants Management Specialist. The Company also updated its procurement policy to ensure that, regardless of the award amount, it files an NFI against the property deed prior to construction of any project in the appropriate public records office of the jurisdiction in which the property is located and provides a copy to the appropriate HRSA Grants Management Specialist. Contact Person: Ela Lena, Chief Executive Officer of Southern Regional Hospital Expected completion date: Provide training to all employees who are relevant to the procurement process of federal contracts by September 30, 2026.
2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the City evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created to ensure vendors are not suspended or debarred. Explanation of d...
2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the City evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created to ensure vendors are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The City immediately began reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: Kassandra Paider, Finance Director Planned completion date for corrective action plan: The City immediately began evaluating procedures and will implement as soon as possible. If the granting agencies have questions regarding this schedule, please call Kassandra Paider, Finance Director, at (920) 793-7274.
CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Katie Ritchie, Clerk Treasurer Contact Phone Number and Email Address: 260-347-7025, kritchie@kendallvillein.gov Views of Responsible Officials: Option 1: “We concur with the finding.” Descript...
CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Katie Ritchie, Clerk Treasurer Contact Phone Number and Email Address: 260-347-7025, kritchie@kendallvillein.gov Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Clerk Treasurer will work with the Fire Chief and City Attorney to create an updated purchasing policy for the Fire Department that will be adopted by the Board of Works. This policy will align with federal regulations The Board of Works will adopt a suspension and debarment procedure to ensure that the awarded vendor is not suspended, debarred, or otherwise excluded from covered transactions. Before the Board of Works awards the bid, the Clerk Treasurer will verify the vendor is not suspended or debarred or excluded from covered transactions, if all is correct the bid will be awarded by the Board of Works, and the City will enter into a written contract with the vendor. Anticipated Completion Date: December 31, 2026 INDIANA STATE
NNEDV management and the finance team have reviewed the current policies regarding sole-source procurement. NNEDV’s leadership team has received training on procurement requirements and the policy manual will be updated to ensure NNEDV’s procurement policy is in line with 2 CFC 200. Anticipated Comp...
NNEDV management and the finance team have reviewed the current policies regarding sole-source procurement. NNEDV’s leadership team has received training on procurement requirements and the policy manual will be updated to ensure NNEDV’s procurement policy is in line with 2 CFC 200. Anticipated Completion Date: 7/31/2026, Responsible Contact Person: Ellen Yin-Wycoff, Assistant VP of Programs & Operations.
Lima City Schools has procurement policies and procedures in place and will ensure that all contracts entered into for purchased services will be sure to follow the board approved procurement policies and procedures. The Lima City Schools will establish appropriate controls to ensure there is no ove...
Lima City Schools has procurement policies and procedures in place and will ensure that all contracts entered into for purchased services will be sure to follow the board approved procurement policies and procedures. The Lima City Schools will establish appropriate controls to ensure there is no overpayment. The board will obtain appropriate price quotes and non-competitive proposals and verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
FINDING 2025-002 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will enhance its procurement procedures to ensure that...
FINDING 2025-002 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will enhance its procurement procedures to ensure that price reasonableness analyses are performed and documented prior to entering into agreements with vendors in accordance with Uniform Guidance procurement requirements. The University will implement the following corrective actions: • Continue to monitor and review procurement policies and procedures for changes in applicable federal requirements and institutional practices. Procurement policies, procedures, and related documentation tools will be updated as necessary, and the standardized procurement checklist will be periodically reviewed and revised to ensure alignment with current procurement policies and Uniform Guidance standards. • Require supervisory review of procurement transactions to ensure all required procurement documentation, including price reasonableness determinations, is completed and retained prior to final approval of vendor agreements. • Provide training to procurement and departmental personnel involved in federally funded procurements regarding Uniform Guidance requirements and documentation standards. • Conduct periodic monitoring of procurement files to verify ongoing compliance with procurement policies, procedures, checklist requirements, and applicable federal regulations. These corrective actions will strengthen the University's internal controls over procurement activities and help ensure compliance with Uniform Guidance requirements related to procurement documentation and vendor selection. Individual(s) Responsible for Corrective Action Plan: Randi Vandegrift, Strategic Sourcing Manager John Skjeveland, Controller Estimated Completion Date: September 30, 2026
Management will implement enhanced procurement controls to strengthen competition, documentation, and justification for procurements to ensure compliance with 2 CFR 200 and internal policy. Actions include: 1. Effective January 1, 2026, Rebuilding Together adopted a revised Procurement Policy that u...
Management will implement enhanced procurement controls to strengthen competition, documentation, and justification for procurements to ensure compliance with 2 CFR 200 and internal policy. Actions include: 1. Effective January 1, 2026, Rebuilding Together adopted a revised Procurement Policy that updates procurement thresholds and outlined the standard for non-competitive procurement, requiring that sole-source determinations meet one of the specific allowable criteria under 2 CFR §200.320(c). 2. Rebuilding Together will further update the Procurement Policy to require that for noncompetitive procurements, management will prepare and retain contemporaneous written justification in the form of a sole-source justification memo demonstrating that the procurement meets one of the allowable criteria under 2 CFR §200.320(c), supported by appropriate documentation such as market research or evidence of exclusivity. The sole-source justification memo will be reviewed and approved by a manager senior to the staff member leading the procurement before the determination is finalized. 3. Rebuilding Together has developed standardized Micro-Purchase and Small-Purchase Procurement Memo templates that require documentation, at the time of procurement, of vendor selection rationale, price/cost reasonableness, competitive quotes obtained (as applicable), conflict-of-interest certification, and debarment/suspension verification. 4. Rebuilding Together is finalizing a Speaker Procurement SOP, which provides speaker-specific procurement guidance in accordance with 2 CFR 200. 5. Relevant staff (Development, Development Operations, Network Advancement, Communications, Grant Operations, and Finance) will receive training on the revised Procurement Policy and Speaker Procurement SOP. Anticipated Completion Date: The revised Procurement Policy became effective January 1, 2026. Additional edits to the Policy will be made implemented by September 15, 2026. Finalization of the Speaker Procurement SOP and related staff training are anticipated to be completed by December 31, 2026. Responsible Contact Person: Emma Weltzer, Director, Development Operations & Federal Grants
The Company will enhance the existing procurement policy for grant-funded purchases to align with federal procurement guidelines. Price quotations and comparisons will be obtained from an adequate number of vendors and such quotations and comparisons will be retained to support vendor selection. Ant...
The Company will enhance the existing procurement policy for grant-funded purchases to align with federal procurement guidelines. Price quotations and comparisons will be obtained from an adequate number of vendors and such quotations and comparisons will be retained to support vendor selection. Anticipated Completion Date: 12/31/2026 Responsible Contact Person: Rebecca Horn, Controller
Corrective Action Plan Finding No.: 2025 - 002 Condition: The District procured $885,950 of services from a food service vendor and did not follow the formal methods of procurement outlined in 2 CFR 200.320(b)(2), 105 ILCS 5/10-20.21, and their established procurement policy as they did not procure ...
Corrective Action Plan Finding No.: 2025 - 002 Condition: The District procured $885,950 of services from a food service vendor and did not follow the formal methods of procurement outlined in 2 CFR 200.320(b)(2), 105 ILCS 5/10-20.21, and their established procurement policy as they did not procure the services through a competitive request for proposal process. Plan: While the district did obtain a two-year waiver from the Illinois State Board of Education regarding Food Service procurement regulations, management concurs with the finding. The District will strengthen its procurement procedures to ensure purchases subject to the Uniform Guidance procurement requirements are conducted using the appropriate procurement method and adequately documented. Management will provide additional training to personnel responsible for federal procurements and implement a review process to verify compliance with federal procurement requirements prior to contract award. These procedures will be implemented for all applicable procurements beginning in fiscal year 2027. Anticipated Date of Completion: August 30, 2026 Name of Contact Person: Mr. Harrison Neal, Assistant Superintendent of Business and Finance
Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 252MN101S2514 – 2025 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbe...
Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 252MN101S2514 – 2025 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55250010 and H58260061 Compliance Requirement: Procurement Award Period: 2025 Recommendation: We recommend the County follow their federal purchasing policy in all their federal programs and retain documentation of that process occurring. As necessary, the County may need to add internal controls that are specific to each program to ensure this properly occurs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will continue to work with program managers to understand and adhere to federal purchasing policies. Name of the contact person responsible for corrective action: Dana DeMaster, Director of Employment & Economic Assistance Planned completion date for corrective action plan: December 31, 2026
FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Description: Procurement and Suspe...
FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Description: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.027A- Grants to States; 84.173A- Preschool Grants H027 A230073 (Year: 2024), H027 A240073 (Year: 2025), H173A240081 (Year: 2025) $4,500 A review of expenditures charged to the Special Education Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The School District has evaluated and improved internal control procedures by processing expenditures through the approved financial management system to ensure that required procurement methods are properly identified and followed and required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. Estimated Completion Date: June 30, 2026 Contact Person: Anthony Parrillo, Chief Financial Officer Telephone: 912-739-3544 Email: aparrillo@evanscountyschools.org
Condition: For two projects procured during the year ended December 31, 2025, the Township did not obtain competitive bids or quotes for the project as required by 2 CFR 200.320. Planned Corrective Action: The Township will implement processes and procedures to ensure that vendors used on projects f...
Condition: For two projects procured during the year ended December 31, 2025, the Township did not obtain competitive bids or quotes for the project as required by 2 CFR 200.320. Planned Corrective Action: The Township will implement processes and procedures to ensure that vendors used on projects funded with federal grants follow the procurement rules as required by the federal standards. Contact person responsible for corrective action: Barbara Miller, Accounting Mgr. Anticipated Completion Date: 9/30/2026
Finding #2025-015 14.850 Public Housing Operating Fund Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action AMP 1 Response: For Items #2 and #4, management concurs with the finding. Management acknowledges that required documentation verifying that co...
Finding #2025-015 14.850 Public Housing Operating Fund Procurement and Suspension and Debarment Views of Responsible Officials and Planned Corrective Action AMP 1 Response: For Items #2 and #4, management concurs with the finding. Management acknowledges that required documentation verifying that contractors were not suspended, debarred, or excluded was not maintained in the files. Management will conduct a review of contracts to ensure required documentation is obtained and properly filed and will update internal policies to include a checklist to ensure compliance prior to contract execution. • Documentation Review: We will conduct a thorough review of our contracts and ensure that all necessary debarment, suspension, or exclusion from receiving or participation in federal awards are obtained and properly filed. • Policy Improvement: We will update our internal policies to include a checklist for all new contracts, which will ensure that documentation related to debarment, suspension, or exclusion is acquired before proceeding. For Items #2, #4, and #5, management concurs with the finding related to Independent Cost Estimate documentation. Management acknowledges that documentation supporting cost estimates was not maintained prior to solicitation. Management will implement a standardized process for documenting Independent Cost Estimates and will conduct periodic reviews to ensure compliance. We acknowledge the lack of documentation on the Independent Cost Estimate (ICE) procedures prior to solicitation. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. Moving forward, we will implement measures to ensure that appropriate documentation is created and maintained for all cost estimates. This includes developing a standardized process for documenting ICE procedures and conducting regular reviews to ensure compliance. For Item #15, management does not concur with the finding. Management states that documentation supporting the Independent Cost Estimate was included in Purchase Order No. PO251039. Management refers to the Small Procurement Abstract/Price Analysis Form, which documents prior pricing information used to support cost reasonableness. Small Procurement Abstract/Price Analysis Form that shows ICE information detailing the last price paid for Consumable Inventory. AMP 2 Response: We acknowledge the need to strengthen monitoring controls to ensure full compliance with applicable procurement, suspension, and debarment requirements. We recognize that verification of contractor eligibility and proper documentation of procurement actions are essential components of an effective internal control system. We acknowledge that documentation of the required suspension and debarment verification was not included in the procurement file at the time of purchase. Although this verification was completed after the fact, we have now confirmed through SAM.gov that the vendors involved were not suspended, debarred, or otherwise excluded from receiving federal funds. To prevent this issue going forward, we have implemented a strengthened control requiring staff to perform and document SAM.gov verification prior to every procurement action, including micro purchases. Verification results will be printed or saved as PDF and filed with each procurement record to ensure full compliance with 2 CFR 200.214 and HUD procurement requirements. These corrective measures will ensure that all future procurements include timely and complete documentation of suspension and debarment checks. Corrective Actions Implemented 1. Suspension & Debarment Verification Controls Strengthened Effective immediately, we have implemented enhanced procedures requiring Housing Administrative Officer personnel to verify all prospective contractors and vendors against the SAM.gov Exclusions Database prior to award. 2. Enforcement of Minimum Solicitation Requirements AMP 2 has reinforced compliance with 5 GCA Chapter 5 and internal procurement SOPs requiring minimum solicitation thresholds: • Three written quotes for small purchases above the micro purchase threshold. • Written justification for any noncompetitive procurement, including emergency, sole source, or inadequate competition. • Staff have been retrained on documentation standards, including price reasonableness, vendor selection rationale, and procurement history requirements. 3. Strengthened Management Oversight and File Review To prevent recurrence, AMP 2 will review all required documentation—including SAM verification, solicitation records, and justifications—is complete. GHURA is committed to maintaining a procurement system that is transparent, compliant, and fully aligned with federal and local requirements. These corrective actions strengthen internal controls, ensure proper oversight, and prevent recurrence of the deficiencies identified. AMP 3 Response: For Items #6 (PO251249) and #10 (PO250104), management does not concur with the finding. Management explains that the purchase orders were structured similarly to indefinite delivery/indefinite quantity arrangements to support recurring and variable requirements throughout the fiscal year. Management states that Housing Administrative Officers solicited pricing from multiple qualified vendors at the beginning of the fiscal year to establish competitively awarded pricing schedules. By securing pricing in advance, management was able to address anticipated needs efficiently without preparing separate Independent Cost Estimates for each task, while maintaining fair and reasonable pricing through competition. For Item #22 (BPA250203), management concurs with the finding. Management noted that the blanket purchase agreement was established to support anticipated advertisement services related to the opening and closing of the AMP3 waitlist. At the time, management determined that only one vendor provided hard-copy print publication services locally and was uncertain whether electronic-only media outlets met program needs. Based on this determination, the agreement was executed. However, management acknowledges that the procurement file should have included documentation of market research performed. Management will ensure that future procurement files include adequate documentation of solicitations, market research, and any sole-source or limited-source justifications, as applicable. AMP 4 Response: AMP4 consistently adheres to all procurement policies and requirements prior to executing contracts, agreements, or purchases. Staff will continually ensure documentation is complete and concise with all procurement procedures. AMP4 Response to items: Item #8. We disagree with this finding. Documentation was completed to continue procurement services. See attached documentation labeled as “#8”. Item #s 17, 19, and 20. We disagree with this finding. Documentation on file to support procurement transactions being conducted in a manner that provided for full and open competition. See attached documentation labeled as “#17, #19, #20”. Item # 23. We disagree with this finding. Documentation on file to show evidence services were awarded equally among multiple vendors. See attached documentation labeled as “#23”. Responsible Party: Asset Management Property Site Managers – Jeanna Blas, AMP 1 Acting, Gina Cura, AMP 2, Patrick Bamba, AMP 3, and Bernadette Tyquiengco, AMP 4 Anticipated Date of Completion: September 30, 2027
FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The...
FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.
Management agrees with the finding and acknowledges that procurement approval documentation was not consistently retained during the audit period. Management notes that the finding primarily relates to documentation and retention of approval evidence, including reliance on verbal approvals and docum...
Management agrees with the finding and acknowledges that procurement approval documentation was not consistently retained during the audit period. Management notes that the finding primarily relates to documentation and retention of approval evidence, including reliance on verbal approvals and documentation gaps associated with system transitions. To address this finding, management has implemented corrective actions requiring documented, written approval for procurements prior to execution. The organization will use standardized approval workflows to ensure procurement approvals are properly evidenced, retained, and available for audit review. Management has also established a centralized repository for procurement records to improve accessibility, consistency, and document retention. In addition, management will enhance data backup and migration procedures to reduce the risk of documentation loss during future system transitions. These procedures will be incorporated into formal policies and standard operating procedures. Management will monitor compliance to ensure procurement documentation and approval controls are consistently followed across federally funded programs. Anticipated Implementation Date: Implemented and ongoing; formal policy incorporation expected by September 1, 2026. Contact Person Responsible for Corrective Action: Shahara Wright, Chief Operating Officer & General Counsel and Brook Abitz, Director of People and Operations
FA 2025·001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Titte: Federal Award Number: Questioned Costs: Description: Procurement Suspensio...
FA 2025·001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Titte: Federal Award Number: Questioned Costs: Description: Procurement Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 255GA324N1199 (Year: 2025), 255GA324L1603 (Year: 2025) $6,267 A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: To address this deficiency and prevent recurrence, the District will implement the following corrective actions: 1. Immediate Reinforcement of Quote Requirements Effective immediately, all School Nutrition and applicable district staff will be required to obtain and document price or rate quotations from a minimum of two qualified sources for all. 2. Pre-Approval and Verification Controls A pre-payment review process will be enforced requiring verification that: o Required quotes are documented o Procurement method aligns with federal thresholds o Vendor selection is properly justified o Payments will not be approved without complete documentation. 3. Staff Training and Accountability Mandatory training will be conducted for all School Nutrition Managers and staff involved in procurement to reinforce: o Federal procurement requirements o Documentation expectations o Internal control procedures Estimated Completion Date: July 31, 2026 Contact Person: Matoshia Grant, School Nutrition Director Telephone: 478-986-1390 Email: Matoshia.grant@jones.k12.ga.us Signature:Tonya Merritt Title: Cheir Financial Officer
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