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 regulaons allow for informal procurement methods when the value of the procurement for property or
services does not exceed the simplified acquision threshold, which is customarily set at $250,000. However,
Indiana Code 5-22-8 has a more restricve 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 acquision threshold. Micro-purchases may be awarded
without solicing compeve price rate quotaons. If small purchase procedures are used, then price or rate
quotaons 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