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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
The Corporation’s legal counsel is currently working to draft amendments to those contracts discovered during the audit process that did not contain specific Uniform Guidance (2 CFR § 200.327 and 2 CFR Part 200, Appendix II) provisions referenced in the finding narrative. The Corporation expects the...
The Corporation’s legal counsel is currently working to draft amendments to those contracts discovered during the audit process that did not contain specific Uniform Guidance (2 CFR § 200.327 and 2 CFR Part 200, Appendix II) provisions referenced in the finding narrative. The Corporation expects these amendments to be finalized and executed by the end of March 2026. Anticipated Completion Date: March 31, 2026 Contact Person: Justin Medeiros, Senior Controller / CFO, Rhode Island Commerce Corporation justin.medeiros@commerceri.com
The Shaquille O'Neal Foundation acknowledges the observation regarding the documentation requirements under 2 CFR §200.318(a). While the Foundation did not have a formal written procurement policy in place during the audit period, it did implement procurement practices designed to comply with the Un...
The Shaquille O'Neal Foundation acknowledges the observation regarding the documentation requirements under 2 CFR §200.318(a). While the Foundation did not have a formal written procurement policy in place during the audit period, it did implement procurement practices designed to comply with the Uniform Guidance requirements. Specifically, the Foundation maintained oversight of contractor performance in accordance with 2 CFR §200.318(b) by ensuring that all contractor agreements and applicable purchase orders incorporated the required federal contract provisions and procurement language. The Foundation monitored contractor performance to verify that work was completed in accordance with the terms, conditions, and specifications of each agreement. The Foundation recognizes that documenting these procurement procedures in a formal written policy is a separate requirement under 2 CFR §200.318(a). To address this deficiency, management has developed and adopted a written Procurement Policy that aligns with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200). The policy formalizes the Foundation's procurement procedures, internal controls, competition requirements, contract oversight responsibilities, and documentation standards to ensure ongoing compliance with federal regulations. Management believes this corrective action fully addresses the audit finding and strengthens the Foundation's procurement governance for future federal awards.
2025-005: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding...
2025-005: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: I. Procurement, Suspension, and Debarment Condition: During testing of procurement activities within the Child Nutrition Cluster, we selected three purchases for review. For all three purchases tested, the District did not perform and document the procurement procedures required under federal regulations to obtain written price quotations. Specifically, the District was unable to provide evidence demonstrating that applicable procurement requirements, including obtaining and documenting competition as required by federal procurement standards, were followed prior to making the purchases. Action planned in response to finding: The District will ensure proper bidding procedures are followed for all purchases exceeding $10,000 in compliance with the Uniform System of Financial Records (USFR) and federal compliance. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edward Dickie, Business Manager.
2025-004: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding...
2025-004: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: I. Procurement, Suspension, and Debarment Condition: During testing of procurement activities within the Child Nutrition Cluster, we selected three purchases for review. For all three purchases tested, the District did not perform and document the procurement procedures required under federal regulations to obtain written price quotations. Specifically, the District was unable to provide evidence demonstrating that applicable procurement requirements, including obtaining and documenting competition as required by federal procurement standards, were followed prior to making the purchases. Action planned in response to finding: The District will ensure proper bidding procedures are followed for all purchases exceeding $10,000 in compliance with the Uniform System of Financial Records (USFR) and federal compliance. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Jim Serbin, CFO.
Contact Persons – Greg Welch, Finance Director& Jarek Wigness, City Engineer Corrective Action Plan – City officials have already implemented internal controls to ensure the proper oversight of federal programs according to the Uniform Grant Guidance Policy for Federal Revenue Sources. Completion Da...
Contact Persons – Greg Welch, Finance Director& Jarek Wigness, City Engineer Corrective Action Plan – City officials have already implemented internal controls to ensure the proper oversight of federal programs according to the Uniform Grant Guidance Policy for Federal Revenue Sources. Completion Date – Ongoing
2025-002 PROCUREMENT (repeat comment) Planned Corrective Action: LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards...
2025-002 PROCUREMENT (repeat comment) Planned Corrective Action: LCCMH Management has taken actions to revise policies and procedures to ensure their alignment with federal regulations, as well as providing training regarding federal procurement requirements for the relevant personnel. The Standards Committee, which is responsible for regularly reviewing Policies and Procedures and approving or recommending changes, reviewed and approved the following policy revisions at its November 19, 2024 meeting to maintain compliance with federal regulation standards. 0.1.02.65 Provider Procurement and Best Value Purchasing 01.02.85 Procuring Employment Services Providers, Independent Contractors and Network Providers. The approved policies were also presented at the LCCMH Full Board meeting on November 21, 2024. All LCCMH Staff were advised on December 2, 2024, to review the revised policies and procedures. On April 22, 2025, SAMSHA provided LCCMH written notification identifying the 2023 citation for procurement as resolved. Responsible Party: Emma McQuillan, Chief Financial Officer Completion Date: 12/5/2024
Corrective Action Plan Contact Person: Belinda Harris Clegg, Wolcott Town Clerk & Treasurer Corrective Action: The Selectboard will update their Purchasing Policy to include checking Sam.gov to confirm if a contractor has not been debarred or suspended from receiving federal funds and to request a S...
Corrective Action Plan Contact Person: Belinda Harris Clegg, Wolcott Town Clerk & Treasurer Corrective Action: The Selectboard will update their Purchasing Policy to include checking Sam.gov to confirm if a contractor has not been debarred or suspended from receiving federal funds and to request a Suspension and Debarment certification from the contractor. Anticipated Completion Date: April 30, 2026
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.
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the procurement and suspension and debarment compliance requirements under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173)....
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the procurement and suspension and debarment compliance requirements under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173). The PRDE respectfully clarifies that the Department does have established processes and internal controls related to procurement activities, including those applicable to federally funded programs such as IDEA. The procurement procedures in place are consistent with applicable federal regulations, including 2 CFR §200.317 and 2 CFR §200.318(a)(i), as well as applicable Commonwealth of Puerto Rico laws and regulations. However, the PRDE acknowledges that the timely delivery of procurement documentation and the organization of contract records for IDEA-funded programs require improvement. The deficiencies noted are attributable primarily to delays in making documentation available to the auditors within the requested timeframes, and to the need for improved coordination between the IDEA program office and the Purchase Department of PRDE, which handles certain quotation processes IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Enid Diaz Nieves Executive Director III Administration and Transportation Unit Alayra Figueroa Gonzalez Associate Secretary for Special Education
Management has since adopted a formal policy stipulating compliance with State of Mississippi procurement and Federal procurement requirements. A written standard of conduct for employees engaged in contract selection, award, and administration is in process and expected to be formally adopted in th...
Management has since adopted a formal policy stipulating compliance with State of Mississippi procurement and Federal procurement requirements. A written standard of conduct for employees engaged in contract selection, award, and administration is in process and expected to be formally adopted in the near future. Completion Date: Pending Name of Contact Person Responsible for Corrective Action Plan: Rachel Quave
Condition: The Corporation’s procurement and suspension/debarment policies and procedures were not in conformance with Uniform Guidance requirements. In addition, procurement records for the items tested did not contain sufficient documentation to support the procurement method used, the basis for c...
Condition: The Corporation’s procurement and suspension/debarment policies and procedures were not in conformance with Uniform Guidance requirements. In addition, procurement records for the items tested did not contain sufficient documentation to support the procurement method used, the basis for contract selection, or compliance with suspension and debarment requirements. Planned Corrective Action: The Corporation will update and formally adopt written procurement, suspension, and debarment policies and procedures to conform to Uniform Guidance requirements and should implement procedures to ensure those policies are consistently followed and documented for all federally funded procurements. Contact person responsible for corrective action: Michelle Toups and Brian Balutanski Anticipated Completion Date: 1/1/2027
Finding 2025-001 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: 2 CFR 200.327 and Appendix II to part 200 require that certain provisions, including the Davis-Ba...
Finding 2025-001 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: 2 CFR 200.327 and Appendix II to part 200 require that certain provisions, including the Davis-Bacon Act and Contract Work Hours and Safety Standards Act (CWHSSA), be included in covered contracts when applicable. The County did not include the Davis-Bacon Act and CWHSSA provisions in a construction contract executed in fiscal year 2025, and a process had not been established to review grant contracts for all relevant provisions. Responsible Individuals: Elijah Anderson, County Auditor Corrective Action Plan: Taylor County will add a step for contract review performed by the Auditor’s Office, in collaboration with the Taylor County ADA for Civil Matters, to verify all required federal contract provisions all included in contracts before they are approved by the Commissioners Court. Anticipated Completion Date: Ongoing. Item has been identified, with internal discussion on best practice to implement the contract review.
Federal Agency Name: Department of Treasury Pass-through Agency: State of Indiana Office of Community and Rural Affairs Assistance Listing Number: 21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified: • The Entity’s formally documented pro...
Federal Agency Name: Department of Treasury Pass-through Agency: State of Indiana Office of Community and Rural Affairs Assistance Listing Number: 21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: Testing of the federal program identified: • The Entity’s formally documented procurement policy was missing the required elements detailed under Uniform Guidance. • Four instances where the Entity did not follow the procurement process and did not have any formal documentation in place with vendors. • Four instances where the Entity 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. Responsible Individuals: Sara Morris, Chief Financial Officer and Jay Watkins, Sr. Vice President of Broadband Services Corrective Action Plan: Management will update their procurement policy to ensure it includes all required elements in accordance with Uniform Guidance. In addition, management will implement procedures and control processes related to the review of procurement to ensure the procurement methods are being followed and documentation isretained to support compliance. Management will also ensure vendors are not suspended or debarred from doing business with the federal government prior to entering into a procurement transaction. Anticipated Completion Date: October 2026
Going forward, Lighthouse Louisiana will ensure that its procurement policy reflects its commitment to purchases made in a manner that promotes full and open competition, supports price reasonableness, and maintains appropriate documentation based on the applicable procurement threshold. Management ...
Going forward, Lighthouse Louisiana will ensure that its procurement policy reflects its commitment to purchases made in a manner that promotes full and open competition, supports price reasonableness, and maintains appropriate documentation based on the applicable procurement threshold. Management confirms that the Organization will apply a $10,000 micro-purchase threshold, require price or rate quotations from an adequate number of qualified sources for small purchases between $10,000 and $250,000, and require a formal competitive process for procurements exceeding $250,000, unless a properly documented exception applies. Lighthouse Louisiana did not actively retain all SAM.gov search results in vendor files for each vendor included in the procurement testing; however, if a SAM.gov verification was performed but not retained in the file, management will document the issue, perform and retain an updated verification, and strengthen internal controls to require retention of SAM.gov evidence before agreement execution or renewal. As part of its corrective action, Lighthouse Louisiana will enhance its procurement file review process to ensure that each grant-funded procurement contains, as applicable, the procurement method determination, supporting quotes or price comparisons, price reasonableness analysis, vendor selection rationale, required approvals, contract or agreement, and SAM.gov verification. Management will also reinforce staff training on procurement documentation requirements and will implement a standardized procurement checklist for grant-funded purchases. The Chief Financial Officer, Chief Operations Officer, and Project Director will be responsible for ensuring that any requested documentation is gathered and submitted to the auditors and that procurement file improvements are implemented prospectively.
Finding: Procurement, Suspension & Debarment: Congressional Grants - One procurement transaction for a building construction contract which covers 100% of the major program expenditures was tested. We noted that the expenditures of the major program were for valid allowable activities and costs howe...
Finding: Procurement, Suspension & Debarment: Congressional Grants - One procurement transaction for a building construction contract which covers 100% of the major program expenditures was tested. We noted that the expenditures of the major program were for valid allowable activities and costs however, we noted that the procurement, suspension and debarment requirements for a procurement transaction over the simplified acquisition threshold were not followed including, not obtaining competitive bids, missing cost/price analysis, and selecting the contractor primarily on qualifications but without a valid noncompetitive justification. Also, the suspension and debarment search was not conducted. valid. Management is in agreement with this finding. Below is the corrective action plan Views of Responsible Officials and Corrective Action Plan: Management acknowledges that procurement procedures did not fully comply with federal requirements for procurements exceeding the simplified acquisition threshold. Specifically, required elements such as competitive bidding, cost/price analysis, formal justification for noncompetitive procurement, and suspension and debarment verification were not consistently performed or documented. To address this matter, management will implement the following corrective actions: • Formalized Procurement Policy Update: Update and formalize procurement policies to align with federal grant requirements, including specific guidance for procurements exceeding the simplified acquisition threshold. • Competitive Procurement Procedures: Require documented competitive bidding or proposals for all applicable procurements unless a valid and documented sole-source or noncompetitive justification is approved in advance. • Cost/Price Analysis Requirement: Implement a standard requirement to perform and document cost or price analysis for all significant procurement transactions. • Suspension and Debarment Verification: Require documented verification (e.g., SAM.gov search) that all contractors are not suspended or debarred prior to contract award. • Enhanced Review and Oversight: Implement a secondary review control to ensure all procurement documentation is complete and compliant prior to contract execution and payment. • Training and Compliance Awareness: Provide training to relevant personnel on federal procurement requirements, including documentation standards and compliance expectations. Responsible Official Warren McLean Completion Date: The project was completed on December 30, 2025. Mortenson is the largest contractor in Minnesota, and the 5th largest contractor in the United States. They completed a very complex commercial kitchen, NEON Collective Kitchens, a 25,000 square foot facility, one of the 5 largest commercial kitchens in the country. Going forward, we will adhere to the corrective action plan that we outlined above.
Finding: Reporting: Congressional Grants - The Organization's federal award agreement requires SF-425 Federal Financial Report and a performance report to be filed annually. The Organization did not file these reports in 2025 as required. Views of Responsible Officials and Planned Corrective Actions...
Finding: Reporting: Congressional Grants - The Organization's federal award agreement requires SF-425 Federal Financial Report and a performance report to be filed annually. The Organization did not file these reports in 2025 as required. Views of Responsible Officials and Planned Corrective Actions: Management is in agreement with this finding Below is the corrective action plan Management acknowledges that required grant reporting, including the SF-425 Federal Financial Report and annual performance report, was not submitted in accordance with the federal award agreement. This was due to a breakdown in tracking reporting deadlines and responsibilities. To address this matter, management will implement the following corrective actions: • Centralized Grant Compliance Tracking: Establish a comprehensive reporting calendar that includes all federal grant reporting requirements, due dates, and assigned responsible parties. • Assignment of Accountability: Designate a specific individual responsible for monitoring compliance with all grant reporting requirements and ensuring timely submission of required reports. • Formalized Review and Submission Process: Implement a standardized process requiring preparation, supervisory review, and documented approval of all grant-related reports prior to submission. • Periodic Compliance Monitoring: Conduct periodic (e.g., quarterly) reviews of grant agreements to confirm all reporting requirements are identified, tracked, and fulfilled. • Training and Awareness: Provide training to relevant personnel on federal grant compliance requirements, including reporting obligations and applicable deadlines. Responsible Official: Warren McLean Completion Date: June 30, 2026
Audit Finding Reference: 2025-002 Improve Procurement Procedures Planned Corrective Action: The District will strengthen its procurement procedures for federally funded purchases to ensure compliance with Uniform Guidance requirements. Specifically, the District will: 1. Revise procurement procedure...
Audit Finding Reference: 2025-002 Improve Procurement Procedures Planned Corrective Action: The District will strengthen its procurement procedures for federally funded purchases to ensure compliance with Uniform Guidance requirements. Specifically, the District will: 1. Revise procurement procedures to clearly identify when federal procurement requirements apply in addition to state and local procurement regulations. 2. Develop and implement a federal procurement checklist that must be completed prior to the award of any contract funded in whole or in part with federal grant funds. 3. Work with the Law Department to establish standardized contract templates containing all required federal contract provisions, including the Byrd Anti-Lobbying Amendment when applicable. 4. Require a secondary review bythe Business Office or Grants Management personnel before contract execution to verify compliance with Uniform Guidance procurement standards and required contract clauses. 5. Provide annual training to Business Office staff, grant managers, and other personnel involved in procurement activities regarding federal procurement requirements and contract provisions. 6. Conduct periodic internal reviews of federally funded procurement transactions to ensure ongoing compliance. Planned Implementation Date of Corrective Action: The revised procedures, procurement checklist, and standardized contract templates will be implemented by7 /1/2026. Training will be completed for applicable staff during the current fiscal year and prior to the initiation of future federally funded procurements. Person Responsible for Corrective Action: Assistant Superintendent of Finance Derek Pinto, Assistant Superintendent of Finance
The East Alabama Health Care Authority (the Authority) recognizes the importance of being sufficiently knowledgeable on federal grant requirements. Management acknowledges that while the Authority did complete procurement procedures in compliance with the grant requirements that it did not establish...
The East Alabama Health Care Authority (the Authority) recognizes the importance of being sufficiently knowledgeable on federal grant requirements. Management acknowledges that while the Authority did complete procurement procedures in compliance with the grant requirements that it did not establish formal written policies and procedures addressing procurement methods, competition requirements, and documentations standards to be consistently applied to all procurement transactions under federal awards. To ensure compliance with federal grant awards moving forward, the Authority will document policies regarding unmet requirements described above. Management will ensure that procedures to meet these policies are implemented and that evidence of this implementation is recorded. Contact Person & Proposed Completion Date Contact person responsible for corrective action: Dennis Thrasher VP - Controller (334) 528-2104 Proposed date of completion: 9/30/2026
Finding 2025-003: Inadequate Procurement Documentation Management’s response: Concur Responsible individual: Finance Manager, Executive Director, Board of Directors Anticipated completion date: March 31, 2026 Management agrees with this finding and will implement the following: • Update procurement ...
Finding 2025-003: Inadequate Procurement Documentation Management’s response: Concur Responsible individual: Finance Manager, Executive Director, Board of Directors Anticipated completion date: March 31, 2026 Management agrees with this finding and will implement the following: • Update procurement policies and procedures to align with 2 CFR 200, including: o Develop and implement standardized procurement checklists o Require cost/price analysis for all qualified transactions o Require suspension/debarment checks for all qualified transactions o Require supervisory review and oversight by Board of Directors o Require adherence to document retention and destruction policy
Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of...
Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.
Contact Persons Responsible: Primary – Anthonia Ibe, CFO In Absence (Alternative): – Jesus Infante, CAO Management acknowledges this finding and has developed a corrective action plan to strengthen the underlying control, assign clear ownership, and ensure timely implementation. The Agency will revi...
Contact Persons Responsible: Primary – Anthonia Ibe, CFO In Absence (Alternative): – Jesus Infante, CAO Management acknowledges this finding and has developed a corrective action plan to strengthen the underlying control, assign clear ownership, and ensure timely implementation. The Agency will revise its procurement policy to fully align with the requirements of 2 CFR Parts 200.317-200.327, including procedures for all required procurement methods. This revision is being coordinated with the broader update to the Fiscal Policy and Procedures Manual currently underway to ensure consistency across all organizational policies. The CFO and CAO will work jointly to implement and monitor corrective actions in cross-functional areas, including timekeeping, payroll documentation, record retention, lease tracking, IT access controls, vendor onboarding, procurement documentation, and personnel training. This shared structure is intended to ensure that policy revisions are supported by clear workflows, staff training, documentation standards, and periodic compliance review. We note that no purchases during the audit period met the threshold requiring formal competitive bidding, and no questioned costs were identified. By September 30, 2026, the Agency will complete updates to procurement procedures.
Subject: Corrective Action Plan for FY2025 Audit Action Taken in Response to the Finding The Commission reviewed the two transactions cited in the audit—Adobe Lightroom ($127.07) and Hover ($103.02)—and determined that these small-dollar purchases resulted from unintentional administrative oversight...
Subject: Corrective Action Plan for FY2025 Audit Action Taken in Response to the Finding The Commission reviewed the two transactions cited in the audit—Adobe Lightroom ($127.07) and Hover ($103.02)—and determined that these small-dollar purchases resulted from unintentional administrative oversights rather than systemic issues. To prevent similar issues going forward, the following actions have been taken or are in progress: 1. Clarifying vendor coverage under existing agreements ICPRB maintains a blanket procurement agreement for Adobe products. A detailed review of that agreement confirmed that Adobe Lightroom is not currently covered. Going forward, any Adobe products not explicitly included in an approved blanket agreement will require a separate procurement requisition before purchase. 2. Strengthening controls over procurement thresholds Procedures have been reinforced to ensure that any purchase exceeding the $100 threshold is properly documented before the purchase is made. As part of this effort, a Director of Finance and Administration—who is a CPA—joined the organization effective April 6, 2026, with direct responsibility for overseeing procurement activities and ensuring compliance with applicable policies. 3. Monitoring cumulative spending by vendor In the case of Hover, ICPRB initially incurred a small annual charge of $16.17 for website hosting. Over time, additional sites were added, which caused total spending with the vendor to exceed the $100 threshold by $3.02. New procedures are now in place to monitor cumulative spending with each vendor throughout the year so that procurement requirements are triggered promptly when thresholds are reached. 4. Reinforcing training and communication Finance and administrative staff involved in purchasing and procurement were reminded of key requirements, including: The importance of obtaining proper procurement documentation for applicable purchases. • The need to track cumulative vendor spending to identify when thresholds are exceeded. • The limitations of blanket procurement agreements 5. Conducting periodic compliance reviews The Finance Department will perform regular reviews of vendor expenditures to identify any vendors approaching or exceeding procurement thresholds and will take appropriate action as needed to maintain compliance. Name(s) of the contact person(s) responsible for corrective action: P. Ernest Parker, Jr., Director of Finance and Administration eparker@icprb.org, 301.450.2413 Wendy Wang, Senior Accountant wwang@icprb.org, 301.274.8129 Planned completion date for corrective action plan: June 30, 2026.
Using the DHS Contract Lifecycle Management (CLM) System, the Office of Procurement Services (OPS) reviews all contract requests (new, amendments, renewals, and extensions) for compliance with the State Purchasing Act. During the review, OPS will inform the program of any requests that do not comply...
Using the DHS Contract Lifecycle Management (CLM) System, the Office of Procurement Services (OPS) reviews all contract requests (new, amendments, renewals, and extensions) for compliance with the State Purchasing Act. During the review, OPS will inform the program of any requests that do not comply with the Procurement Rules and Regulations before the contract is fully executed, providing a list of alternative exempt vendors. The contract will be halted until DHS is notified and approval is granted, or until a solicitation is posted and awarded. Senior-level staff in OPS will also review all requisitions for goods not processed through CLM to ensure that purchases comply with the State Purchasing Act. A spend analysis is conducted on purchases not exempt from the State Purchasing Act to determine whether the associated NIGP Code Category is above or below the bid threshold. If the NIGP Code is or may be above the bid threshold, precautionary steps are taken to ensure that the Department of Human Services remains in compliance with the State Purchasing Act (i.e., suggesting exempt vendors, halting the purchase until DHS is notified and approval is granted, or until a solicitation is posted and awarded).
Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the ...
Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the most stringent requirements included in the Uniform Guidance. The organization did not comply with all the documentation requirements laid out in its procurement policy. In addition, the suspension and debarment verification occurred after the contract was entered into, and there was no documentation maintained to demonstrate the monitoring of contract compliance with Build America, Buy America (BABA) Act. Questioned costs: none. Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Rogue River Watershed Council will review 2 CFR 200.318 through 200.327 and update our Procurement Policy to meet the necessary standards. We will strengthen our policy by setting out procedures related to, when required: (1) suspension/ debarment verification of contractors (including the timing of such verification) and (2) required agreement language related to grantrequired stipulations such as BABA requirements, monitoring, compliance, and documentation. Anticipated completion date: We will develop and approve the updated procurement policy by 7/31/2026.
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