2024-002 – Procurement, Suspension, and Debarment Program: ALN# 47.070 = Computer and Information Science and Engineering Federal Agency: National Science Foundation Federal Award Identification Number(s): 2216614, 2122756 Period: Year Ended December 31, 2024 Criteria: Under 2 CFR 200.319, and 2 CFR 200.320, non-federal entities must maintain written procurement policies and internal controls to ensure compliance with Federal requirements, including suspension and debarment checks. Under 2 CFR 200.214, non-federal entities must not enter into contracts with parties that are suspended or debarred. Condition: During our review of procurement policies, we noted that the Organization did not have written procedures addressing procurement suspension and debarment requirements and the Organization was unable to furnish documentation that procurement, suspension, and debarment procedures took place for all contracts selected for testing. Cause: The Organization has not developed formal written procurement, suspension, and debarment policies and procedures. Effect: Without written polices and procedures, the Organization is at increased risk of: • Failing to verify vendor eligibility. • Contracting with suspended or debarred entities. • Procurements conducted in a manner that fails to provide full and open competition. Questioned Costs: No questioned costs identified. Context: This sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: Yes Recommendation: We recommend that the Organization: • Develop and implement written procurement policies that clearly outline procedures for suspension and debarment verification. • Require and document evidence of compliance for all covered procurement transactions • Train staff on the updated procedures. • Periodically review procurement files to ensure consistent adherence. Views of Responsible Officials: See management corrective action plan attached.
COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027, Passed through the Pennsylvania Department of Agriculture, Grant Period - Year ended December 31, 2024. Criteria: Title 2 CFR Section 200.214 of the Uniform Guidance subjects nonfederal entities to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: The District did not verify the parties were not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal programs prior to awarding contracts. Questioned Costs: None. Perspective Information: Not applicable. Effect: Contracts under the federal program may improperly be awarded to excluded or ineligible parties. Cause: The District Manager was not aware of the District’s responsibility to verify that parties were not suspended or debarred. Identification of Repeat Findings: Not applicable. Recommendation: The District should apply the guidance in section 200.214 of the Uniform Guidance in determining whether parties are excluded or ineligible for participation in Federal programs. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: See the County’s corrective action plan.
2024-003 –LACK OF CONTROLS OVER SUSPENSION AND DEBAREMENT - ALN 21.027 – SIGNIFICANT DEFICIENCY FINDING TYPE: SIGNIFICANT DEFICIENCY Finding 2024-003 Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Year(s): SLFRP5402, 2024 Federal Agency: U.S. Department of Treasury Pass Through Agency: North Dakota State Treasurer Office Questioned Cost: $0 Condition Morton County did not have documented policies in place to verify that vendors receiving federal funds were not suspended or debarred from participation in federal programs. During the audit period, the County did not perform checks of the federal System for Award Management (SAM.gov) or obtain certifications from vendors to demonstrate compliance with federal suspension and debarment requirements. Context During the audit period, Morton County entered one contract in the amount of $190,400. The vendor was not on the suspension and debarment listing on SAM.gov. Effect Without documented controls to verify vendor eligibility, the County was exposed to an increased risk of noncompliance with federal requirements. Although no instances of transactions with suspended or debarred parties were identified during audit testing, the lack of controls limits the County’s ability to demonstrate ongoing compliance with suspension and debarment regulations. Cause Morton County was not aware of the requirement to establish and document procedures specific to suspension and debarment compliance under the Uniform Guidance. As a result, controls and documentation practices were not implemented during the audit period. Criteria 2 CFR §200.214 and 2 CFR §180.300 require non-federal entities to verify that parties to covered transactions are not suspended or debarred prior to entering such transactions. Additionally, 2 CFR 200.303 states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Repeat Finding NO. Recommendation We recommend Morton County develop and implement documented procedures to verify vendor eligibility under federal suspension and debarment requirements prior to entering into contracts. Acceptable verification methods include SAM.gov checks, vendor certifications, or contract clauses, and documentation of compliance should be retained. Morton County’s Response See Corrective Action Plan.
ALN 14.251 and ALN 21.027 Finding #2024‐003 Subrecipient Monitoring Repeat Finding: No Condition: The Organization did not perform adequate monitoring of its subrecipient to ensure compliance with federal procurement and suspension/debarment requirements. Specifically: · The subrecipient did not have procurement policies that conform to the Uniform Guidance requirements at 2 CFR 200.317–200.327. · The subrecipient did not perform suspension or debarment verifications for vendors, as required by 2 CFR 200.214. · The Organization, as pass‐through entity, did not identify or address these deficiencies through its monitoring procedures. Criteria: In accordance with 2 CFR 200.332(d), pass‐through entities are required to monitor the activities of subrecipients as necessary to ensure that subawards are used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, 2 CFR 200.317–200.327 establish procurement standards applicable to non‐federal entities, including the requirement to have written procurement procedures that conform to applicable federal law and standards. Under 2 CFR 200.214, non‐federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Cause: The Organization’s monitoring procedures did not include a review of subrecipient procurement policies and practices, nor did they require confirmation that the subrecipient was performing suspension/debarment checks. Effect: There is an increased risk that federal funds could be expended on unallowable costs, including purchases from suspended or debarred vendors. Lack of proper procurement policies also creates a risk that procurements may not be conducted in a manner providing full and open competition, as required by federal regulations. Questioned Costs: None at this time. Perspective Information: The condition noted applied to the subrecipient responsible for administering $1,525,133 of the Organization’s federal expenditures under ALN 14.251 and $900,000 of the Organization’s pass‐through funds expenditures under ALN 21.027. This represents 100% of the Organization’s subrecipient expenditures for the program. Accordingly, the lack of subrecipient procurement and debarment compliance is considered systemic to the subrecipient relationship and not an isolated instance. Recommendation: We recommend that the Organization strengthen its subrecipient monitoring procedures to include verification that subrecipients have procurement policies in compliance with Uniform Guidance and are performing suspension and debarment checks prior to entering into vendor agreements. The Organization should provide training and technical assistance to subrecipients to help them implement compliant procurement and debarment procedures. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization has partnered with a firm to administer the development of the project and was unaware of its responsibilities to monitor the subrecipient relating to procurement and debarment. The Organization is in process of implementing procedures to ensure the subrecipient complies with the requirements of the Uniform Guidance.
Finding #2024‐008 Procurement, Suspension/Debarment Repeat Finding: No Condition: During testing of procurement transactions, it was noted that the Organization did not perform required procurement procedures or suspension/debarment verifications prior to executing contracts funded by federal awards. Specifically, the Organization did not document competitive procurement processes or maintain supporting documentation to demonstrate compliance with Uniform Guidance procurement standards. No evidence was provided that vendors were checked against SAM.gov or otherwise verified to ensure they were not suspended or debarred at the time of award. Criteria: Under 2 CFR 200.317 through 200.327, non‐federal entities must follow procurement standards that promote full and open competition, include written procurement procedures, and maintain records sufficient to detail the history of procurements. Additionally, per 2 CFR 200.214, non‐federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify vendor eligibility by checking the System for Award Management (SAM.gov) or by obtaining a vendor certification prior to award. Cause: The Organization lacked formal procurement policies and internal controls to ensure Uniform Guidance procurement and debarment procedures were followed. Responsibility for compliance was not clearly assigned, and no review process existed to confirm that required verifications were completed. Effect: Failure to follow federal procurement and debarment requirements represents a material weakness in internal control over compliance and increases the risk that: Contracts could be awarded to suspended or debarred vendors; purchases may not reflect fair and open competition; and Federal funds could be expended on unallowable costs. Questioned Costs: None at this time. Perspective Information: This condition applied to all federal procurement transactions tested during the year ended June 30, 2025, totaling approximately $51,520 in expenditures. Recommendation: We recommend that the Organization: · Develop and implement written procurement policies that comply with 2 CFR 200.317–200.327. · Require staff to perform and document SAM.gov checks (or equivalent verification) prior to entering into any federally funded contracts. · Maintain procurement documentation that includes bids, quotes, selection rationale, and evidence of price reasonableness. · Provide training to staff on Uniform Guidance procurement and debarment requirements. · Establish a review and approval process to verify compliance before purchases are finalized. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization will establish formalized financial policies that comply with procurement and debarment requirements of the Uniform Guidance and ensure compliance with such policies when procuring vendors.
FINDING 2024‐002 – Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance and Instance of Material Noncompliance Assistance Listing Number: 21.029 Federal Program Name: COVID-19 - Coronavirus Capital Projects Fund Award Year: 2024 Criteria: Uniform Guidance requires non-federal entities to establish and follow documented procurement procedures and ensure compliance with suspension and debarment requirements. 2 CFR §200.318(a): Requires entities to have and use documented procurement procedures consistent with federal standards. 2 CFR §200.318(i): Requires maintenance of records sufficient to detail the history of procurement. 2 CFR §200.214: Prohibits contracting with parties that are suspended or debarred, requiring verification. Condition and context: The Cooperative has not developed or implemented formal written procurement policies and procedures that comply with Uniform Guidance requirements. Additionally, the Cooperative has not established procedures to ensure compliance with suspension and debarment requirements. As a result, for a sample of three vendors and six procurement transactions tested, the Cooperative did not document suspension and debarment verification (e.g., SAM.gov) for vendors and contractors procured under the federal award. The absence of documented procedures also indicates that procurement activities are not being performed under a standardized framework aligned with federal requirements. Questioned costs: None. Effect: Due to the lack of formalized procurement processes and controls there is an increased risk of noncompliance with federal procurement standards. Expenditures could be paid to suspended or debarred vendors resulting in disallowed expenditures, and noncompliance with the grant agreement. Cause: This was a new grant for the Cooperative, management did not have a sufficient understanding of the procurement-related control requirements necessary to comply with the grant agreement and Uniform Guidance. As a result, procurement processes were not formally established or aligned with federal requirements. Repeat finding: No. Recommendation: We recommend the Cooperative develops and implements written procurement policies and procedures in compliance with 2 CFR §200.318–§200.327, including competitive procurement requirements, cost/price analysis, documentation, and record retention. Establish procedures to ensure compliance with suspension and debarment requirements, including performing SAM.gov verification prior to contract award and retaining documentation of verification in procurement files. Lastly, we recommend implementing monitoring controls to ensure procurement documentation and compliance requirements are consistently met. Views of responsible officials and planned corrective actions: Wabash is currently in the process of formalizing its procurement standards and internal controls. While management previously managed contractor selections through established internal practices, management recognizes the requirement for a comprehensive written procurement policy that explicitly outlines selection criteria and mandatory debarment verification procedures. To remediate the identified material weakness, Wabash will implement a formal Procurement Policy and Procedure by June 30, 2026. Contact Person(s): Jason Griffy, Network Operations Manager Justin Gephart, Chief Operating Officer
FINDING 2024-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Numbers and Years (or Other Identifying Numbers): TRSW 2200305, CY 2024 Pass-Through Entity: Indiana Finance Authority Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods or services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. Verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County had not properly implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. Covered transactions in the amount of $1,454,478 were made during the audit period to three vendors. A total of $60,732 was paid from the CY 2024 award to one vendor, and a total of $1,393,746 was paid from the TRSW 2200305 award to two vendors. Of the three vendors paid by the County, one vendor contract included a suspension and debarment clause with total payments of $917,636 from the TRSW 2200305 award. For the other two vendors, the County did not check the EPLS nor was a certification collected from the vendors, and a clause did not exist in the agreements with the vendors. One of the vendors was paid a total of $60,732 from the CY 2024 award, and the other vendor was paid $476,110 from the TRSW 2200305 award. Although the County had a policy to include a clause in vendor contracts related to covered transactions, a clause was not included in those two contracts and no other documentation to verify the County's compliance with the suspension and debarment federal requirement was provided for audit. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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 200.214 states: "Recipients and subrecipients are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards." Cause The system of internal controls established by management of the County was not implemented as designed, and employees lacked sufficient training to carry out suspension and debarment procedures required to certify vendor status. Effect Without the proper implementation of an effectively designed system of internal controls, the system is incapable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the County was not able to provide documentation that the suspension and debarment requirements were followed for two vendors to whom payment was equal to or in excess of $25,000 was paid. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish a system of internal controls to ensure compliance and comply with the grant agreements and the Procurement and Suspension and Debarment compliance requirement. Additionally, the County should ensure that all necessary personnel understand the requirements and County policies. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
U.S. Department of Treasury, COVID- 19 Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement - Suspension and Debarment and Material Weakness In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. In accordance with 2 CFR Section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition - Suspension and debarment checks were not completed for a vendor prior to entering into a contract. Cause - The City's controls to ensure suspension and debarment checks on vendors receiving federal funds did not operate effectively. Effect - Federal funds could be paid to entities that are suspended or debarred. Questioned Costs - None noted, as the vendor was reviewed and determined to not be suspended or debarred. Context - The City entered into two contracts during the year ended December 31, 2024 that was considered a "covered transaction" and spent approximately $982,000 under this contract. Both contracts selected for testing suspension and debarment and uncovered the City did not check the vendor's suspension and debarment status prior to purchase for the $540,000 contract. The City completed the suspension and debarment check subsequent to purchase and verified the vendor was not suspended or disbarred. Identification as a Repeat Finding, if applicable - None noted. Recommendation - Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors prior to making purchases with federal funds. View of Responsible Official and Planned Corrective Actions - Management agrees with the stated finding and has implemented a corrective action plan.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP0136-2021 Award Period: 3/3/21- 12/31/26 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR § 200.214, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Condition: The City did not have a documented process in place to verify and document suspension and debarment status for vendors paid with federal funds. Questioned costs: None Context: During our testing, it was noted that all samples selected for testing were not reviewed to ensure the contractor’s suspension and debarment status was documented. Cause: This issue was identified through testing of procurement and disbursements related to federal programs. A sample of vendors did not have evidence of suspension and debarment verification. Effect: The City is at risk for noncompliance with Federal grants as it relates to suspension and debarment. Repeat Finding: No Recommendation: We recommend the City implement formal procedures to verify and document suspension and debarment status for all vendors paid with federal funds. Views of responsible officials: Management agrees with the finding and recommendation.
Assistance Listing, Federal Agency, and Program Name - 20.941, U.S. Department of Transportation, Strengthening Mobility and Revolutionizing Transportation (SMART) Grants Program Federal Award Identification Number and Year - SMARTFY22N1P1G34-A01 Pass through Entity - Not applicable Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.214, nonfederal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR part 180 restrict making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition - The Road Commission could not provide evidence that it performed a check to verify contractors were not suspended or debarred. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The Road Commission used the grant to procure services from one contractor, that was paid $1,894,112 with grant funds, and was unable to provide evidence that the check for suspension and debarment was completed prior to entering into a contract with them. Plante Moran reviewed the SAM.gov website noting the vendor was not listed as suspended or disbarred. Cause and Effect - The Road Commission did not retain evidence to support that it had conducted the search for whether a contractor was suspended or debarred prior to entering into a contract. Recommendation - We recommend the Road Commission implement controls to ensure documentation is maintained to support that contractors are not suspended or debarred. Views of Responsible Officials and Corrective Action Plan - The Road Commission will establish formal policies around the internal review of contractors to ensure they are not suspended or debarred. In addition, the policy will ensure formal documentation of this review is maintained in the associated project.
Noncompliance with Procurement, Suspension, & Debarment Standard (Significant Deficiency) Federal Award Program: 21.027 COVID-19: Coronavirus State and Local Fiscal Recovery Funds Criteria: 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.214 prohibits non-federal entities from contracting with parties that are suspended or debarred under covered transactions. Condition and Context: Audit procedures revealed that there was not a policy or process in place to formally document the review of the contracted entity for suspension and debarment prior to entering into the agreement. Cause: The Organization does not have a formal process to document suspension and debarment. Management was unaware of the requirement, though it was clear the management thoughtfully considered the contractor’s reputation and determined that the contractor was suited for the agreement. Effect: The Organization did not perform its review of suspension and debarment for this agreement, though the contractor was found to not be on prohibited lists at annual review. Questioned Costs: None Recommendation: Management should strengthen their processes, controls, and review over suspension and debarment processes, and develop a written policy on such items to ensure compliance with Uniform Administrative Requirements. Views of Responsible Officials and Planned Corrective Actions: As stated by the auditor, SCEC is selective about who to enter contracts with and has long-standing relationships with the organizations we were working with on these efforts, who also had other Federal contracts in process that we were aware of. We have instituted a finance procedure to check all contractors and sub-contractors on the Sam.gov’s verification of debarment and suspension tool before the first payment under the contract is issued and a policy that all SCEC contracts or subawards over $25,000 that utilize federal or state funds must include a suspension and debarment certification.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) 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. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
2024-001 U.S. Environmental Protection Agency/ U.S. Department of Treasury Federal Financial Assistance Listing 66.458 / 21.027 Capitalization Grants for Clean Water State Revolving Funds/ COVID-19 Coronavirus State and Local Fiscal Recovery Funds Procurement Suspension and Debarment Material Weakness in Internal Control Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing over procurement, based upon discussions with management, the City had performed suspension and debarment check prior to entering into the transaction; however, the documentation was not retained, and we were unable to verify this during our testing. Cause: Documentation was not retained to prove the City verified the vendor was not suspended or debarred prior to entering into the transaction. Effect: We were not able to verify suspension and debarment was verified by the City prior to entering into the transaction. Questioned Costs: None reported. Context/Sampling: Nonstatistical sample was used. Repeat Finding from the Prior Year: No Recommendation: As part of the procurement process, we recommend the City retain documentation verifying suspension and debarment was verified prior to entering into transactions required to follow the procurement rules under 2 CFR 200, Section 200.214 Suspension and Debarment. Viewed of Responsible Officials: Management agrees with the finding.
2024-001 U.S. Environmental Protection Agency/ U.S. Department of Treasury Federal Financial Assistance Listing 66.458 / 21.027 Capitalization Grants for Clean Water State Revolving Funds/ COVID-19 Coronavirus State and Local Fiscal Recovery Funds Procurement Suspension and Debarment Material Weakness in Internal Control Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: During our testing over procurement, based upon discussions with management, the City had performed suspension and debarment check prior to entering into the transaction; however, the documentation was not retained, and we were unable to verify this during our testing. Cause: Documentation was not retained to prove the City verified the vendor was not suspended or debarred prior to entering into the transaction. Effect: We were not able to verify suspension and debarment was verified by the City prior to entering into the transaction. Questioned Costs: None reported. Context/Sampling: Nonstatistical sample was used. Repeat Finding from the Prior Year: No Recommendation: As part of the procurement process, we recommend the City retain documentation verifying suspension and debarment was verified prior to entering into transactions required to follow the procurement rules under 2 CFR 200, Section 200.214 Suspension and Debarment. Viewed of Responsible Officials: Management agrees with the finding.
2024-001: PROCUREMENT (repeat comment) Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.969 Certified Community Behavioral Health Clinics Expansion (CCBHC) Grants Criteria: Per 2 CFR section 200.214 and section 180.300; 48 CFR section 52.209-6, when entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not perform a review of sam.gov to ensure that the vendor was not suspended or debarred prior to entering into an agreement with them. A subsequent review of sam.gov was conducted showing that the vendor was not suspended or debarred. Cause/Effect: Management oversight. Questioned Cost: None Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that verification of suspension, debarment or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.
Criteria: Per 2 CFR Section 200.214 and Appendix II to Part 200, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify that a subrecipient is not suspended or debarred at the time of the award, either by checking the SAM.gov exclusion list, collecting a certification or including appropriate contract clauses. Condition and context: During testing of the Alliance’s controls on compliance over subrecipient monitoring and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check prior to making a subaward. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check prior to issuing subawards. Effect: The Alliance was not fully in compliance with the subrecipient monitoring and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over subrecipient monitoring and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.
2024-001 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information Funding Agency: U.S. Department of the Treasury Federal ALN: 21.027 Criteria Per 2 CFR 200.214, non-federal entities are prohibited from contracting with parties that are suspended or debarred. 2 CFR 200.318(i) also states that "subrecipients must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price." Condition The Chamber has a procurement policy in place; however, the Chamber neglected to verify if vendors had been suspended or debarred, in accordance with stated regulations. The Chamber also did not maintain sufficient records to document the rationale for the procurement method used for a transaction exceeding the small purchase threshold. Questioned Costs $25,000 Context A sample of 3 vendors was made from a population of 3 vendors whose expenses exceeded the covered transaction threshold that were charged to the major program. Of the 3 sampled vendors, the Chamber neglected to check the suspension or debarment status of 1 vendor prior to entering a covered transaction of $25,000. A sample of 3 vendors was made from a population of 3 vendors whose total transactions exceeded the small purchase threshold. Of the 3 sampled vendors, the Chamber did not maintain sufficient records to document the rationale of using a noncompetitive procurement method for a small purchase transaction. Cause The Chamber claimed that they had been conducting business transactions with this vendor prior to having a procurement policy in place and did not implement the procurement policy on already developed business relationships. The Chamber also did not consider documenting its rationale for continuing to use the vendor for services that exceeded the small purchase threshold that were charged to the major program. Effect Purchases may have occurred that do not follow the policy, and contracts with vendors that had been suspended or debarred could have been awarded and not detected. The Chamber also did not conduct procurement transaction "in a manner that provides full and open competition," as defined in 2 CFR 200.319(a). Repeat Finding Yes - reference 2023-001. Auditor's Recommendations Tacoma-Pierce County Chamber of Commerce should include a provision in all contracts transacted in conjunction with using funds originating from a federal award grant, with respect to suspension and debarment, communicate all requirements for procurement to staff and establish procedures to verify that vendors are not suspended or debarred. Chamber staff should also perform an independent status check of vendors in sam.gov prior to entering into an agreement and retain the search results. The Chamber should also evaluate its current method of procurement and educate staff that if using funds from a federal award to enter into a transaction exceeding the small purchase threshold, that full and open competition must be facilitated, despite any prior relationships with vendors.
Reportable Finding Considered a Significant Deficiency – Lack of Supporting Documentation for Search for Suspension and Debarment in Procurement Program Name: Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhood Assistance listing #: 84.215K Program year: 2024 Federal Awarding Agency: Department of Education Compliance requirement: Procurement Criteria: According to 2 CFR §200.214, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. The primary method for ensuring compliance with this requirement is to perform a vendor search on SAM.gov. Other methods include having vendors self-certify or including a clause in the vendor contract. Condition: During our testing of procurement, it was noted that the Organization lacked support documenting a search for suspension or debarment of its vendors or use of the other methods for ensuring compliance. Cause: Policies and internal controls over procurement were not fully functioning during the year, due in part to turnover in the positions that were in charge of procurement. Effect: The risk of engaging a vendor who is suspended or barred from receiving federal funding or participating in federal award activities is increased. Questioned costs: There are no questioned costs related to this finding. Repeat finding: This is not a repeat finding. Recommendation: We recommend that the Organization update their policies and procedures surrounding procurement to require that one of the methods described above is utilized to ensure that no federal funding is passed to individuals or corporations that are barred from receiving it. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
2024-001: PROCUREMENT, SUSPENSION, AND DEBARMENT Type: Considered a significant deficiency in internal control over compliance/noncompliance Program: ALN 93.788 Opioid STR Criteria: Pursuant to 2 CFR 200.320, when a procurement transaction under a Federal award exceeds the simplified acquisition threshold, either formal procurement methods, or documentation of noncompetitive procurement, are required. Pursuant to 2 CFR 200.214 and 2 CFR part 180, prior to entering into a covered transaction, a nonfederal entity must verify that the person with whom they intend to do business is not suspended, debarred, or otherwise excluded or disqualified. Condition: The CMHSP did not document the noncompetitive procurement process pursuant to 2 CFR 200.320 prior to entering into a contract for services under the grant. Also, the CMHSP did not verify that the vendor was not suspended, debarred, or otherwise excluded or disqualified in accordance with 2 CFR requirements prior to entering into a contract for services under the grant. Cause/Effect: Management oversight. Questioned Cost: None Context: Due to an immediate, unexpected need for specialized services, the CMHSP entered into a contract with a vendor established with the PIHP, but did not document the noncompetitive procurement process pursuant to 2 CFR 200.320. Also, upon subsequent review, it was determined that the vendor was not suspended, debarred, or otherwise excluded or disqualified. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that formal procurement methods are documented and verification of suspension, debarment, or exclusion is conducted prior to entering into a contract. Management’s Resp: Management is in agreement with this recommendation.
Criteria - According to the Coronavirus State and Local Recovery Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under the program. Condition - During our testing, it was noted that 1 of 5 of the vendor selections tested for this program did not have suspension and debarment evaluated or documented prior to the purchase. In addition, there was no formal control policy for the Town to evaluate and document suspension and debarment for expenditures in this program. Cause - The Town was unaware of this requirement applied to CSLRF funding under the revenue replacement method. Effect - In this case, there is no indication that the vendor in question was actually suspended or debarred. However, by not evaluating suspension and debarment for the expenditures of this program, expenditures could be made that do not comply with the program requirements for suspension and debarment. Recommendation - We recommend that suspension and debarment be evaluated and documented for all expenditures made for this program and that a formal control policy for suspension and debarment be considered for such purchases.
Criteria - According to the Coronavirus State and Local Recovery Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under the program. Condition - During our testing, it was noted that 1 of 5 of the vendor selections tested for this program did not have suspension and debarment evaluated or documented prior to the purchase. In addition, there was no formal control policy for the Town to evaluate and document suspension and debarment for expenditures in this program. Cause - The Town was unaware of this requirement applied to CSLRF funding under the revenue replacement method. Effect - In this case, there is no indication that the vendor in question was actually suspended or debarred. However, by not evaluating suspension and debarment for the expenditures of this program, expenditures could be made that do not comply with the program requirements for suspension and debarment. Recommendation - We recommend that suspension and debarment be evaluated and documented for all expenditures made for this program and that a formal control policy for suspension and debarment be considered for such purchases.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2024-005 Significant Deficiency in Internal Controls over Compliance and Noncompliance - Procurement, Suspension and Debarment Federal Agency: Department of Treasury Pass through Grantor: Multiple Federal Program(s): COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number(s): 21.027 Criteria: In accordance with 2 CFR 200.320 Procurement methods paragraph (b), formal procurement methods are required when the value of the procurement transaction under a federal award exceeds the simplified acquisition threshold of the recipient or subrecipient. Additionally, 2 CFR 200.214 outlines the suspension and debarment requirements for non-federal entities receiving federal funds. It mandates that these entities must not engage in "covered transactions" with individuals or organizations that are suspended, debarred, or otherwise excluded from participating in federal programs. Condition/Context: For one vendor, based on the services to be provided, management was required to issue a public notice solicitation in accordance with the required 2 CFR 200 regulations; however, such a notice was not solicited. Additionally, management did not perform a suspension and debarment check prior to work performed with the vendor. Cause: Due to the infrequency of entering into contracts above the simplified acquisition threshold, management was in the process of formally adopting a procurement policy and did not formalize the steps that would have included the procurement policy of the simplified acquisition threshold and formalize suspension and department checks. Effect: Grant funded contracts could be awarded to vendors that are less cost effective and suspended/debarred, which would be in violation of federal regulations and may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Costs: None. Recommendation: Management should implement a formal policy outlining the procurement threshold and the requirement of a Suspension and debarment check in accordance with 2 CFR.200 requirements. Repeat Finding: No. Views of Responsible Officials: See Corrective Action Plan.