Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
Criteria: The Code of Federal Regulations §200.318 required that entities must have and use documented procurement procedures that conform to the procurement standards identified in §200.317 through §200.327. These procedures must include written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180 300). The Code of Federal Regulations (2 CFR 200.318(I)) requires that each non-Federal entity 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 Organization does not have written procurement policies in accordance with procurement requirements contained within the Uniform Guidance including policies and procedures in place to ensure that before entering into a covered transaction the Organization perform the necessary verifications of suspended or debarred entities. The Organization did not maintain sufficient documentation of its procurement decisions and maintain sufficient documentation of its procurement decisions. Cause: The Organization's federal funding significantly increased in the year ended June 30, 2024 and is the first year that the Organization was required to undergo an audit in accordance with the Uniform Guidance that included a procurement requirement. The Organization has existing purchasing and conflict of interest policies in place; however, it was not aware that its existing purchasing policies were required to be updated to explicitly comply with the standards in the Uniform Guidance. As well as, the Organization does not have procedures in place to ensure suspension and debarment checks are completed prior to entering into purchase or service agreements with vendors and updated on an annual basis. Evidence of actions taken to ensure proper suspension and debarment requirements were not being maintained by the Organization. Effect: In the absence of an appropriately written policy, it is more likely that the Organization's procurement practices will not comply with the Uniform Guidance. The Organization did not comply with the procurement standards concerning suspension and debarment and documentation of procurement activities. Recommendation: A written procurement policy in compliance with federal guidelines and a written standard of conduct should be established in accordance with procurement requirements contained in the Uniform Guidance. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
2024-005 - Procurement and Suspension and Debarment Federal Program Information: Department of Treasury - State & Local Fiscal Recovery Fund ALN - 21.027 - State & Local Fiscal Recovery Fund Criteria: The following CFR(s) apply to this finding: 2 CFR §200.318(a) Condition: During our testing we reviewed the procurement policy for the City and identified multiple provisions required were not included in the policy. Cause: The control lapse occurred because there was turnover in key positions and the policy has not been reviewed. Effect: Procurement activities conducted under this incomplete policy may not adhere to required federal standards, increasing the risk of noncompliance, unallowable costs or procurement practices that do not ensure fair and open competition. Identification of Questioned Costs: None identified. Context: The procurement policy in effect during the fiscal year was reviewed which is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City revise its procurement policy to fully incorporate all elements required by 2 CFR §200.317-200.327. Additionally, we suggest the City implement a regular policy review process to ensure continued compliance with federal regulations. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the City.
2024-005 - Procurement and Suspension and Debarment Federal Program Information: Department of Treasury - State & Local Fiscal Recovery Fund ALN - 21.027 - State & Local Fiscal Recovery Fund Criteria: The following CFR(s) apply to this finding: 2 CFR §200.318(a) Condition: During our testing we reviewed the procurement policy for the City and identified multiple provisions required were not included in the policy. Cause: The control lapse occurred because there was turnover in key positions and the policy has not been reviewed. Effect: Procurement activities conducted under this incomplete policy may not adhere to required federal standards, increasing the risk of noncompliance, unallowable costs or procurement practices that do not ensure fair and open competition. Identification of Questioned Costs: None identified. Context: The procurement policy in effect during the fiscal year was reviewed which is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City revise its procurement policy to fully incorporate all elements required by 2 CFR §200.317-200.327. Additionally, we suggest the City implement a regular policy review process to ensure continued compliance with federal regulations. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the City.
2024-005 - Procurement and Suspension and Debarment Federal Program Information: Department of Treasury - State & Local Fiscal Recovery Fund ALN - 21.027 - State & Local Fiscal Recovery Fund Criteria: The following CFR(s) apply to this finding: 2 CFR §200.318(a) Condition: During our testing we reviewed the procurement policy for the City and identified multiple provisions required were not included in the policy. Cause: The control lapse occurred because there was turnover in key positions and the policy has not been reviewed. Effect: Procurement activities conducted under this incomplete policy may not adhere to required federal standards, increasing the risk of noncompliance, unallowable costs or procurement practices that do not ensure fair and open competition. Identification of Questioned Costs: None identified. Context: The procurement policy in effect during the fiscal year was reviewed which is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City revise its procurement policy to fully incorporate all elements required by 2 CFR §200.317-200.327. Additionally, we suggest the City implement a regular policy review process to ensure continued compliance with federal regulations. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the City.
Condition: Expenditures for federal programs did not follow the non-federal entities procedures before entering a covered transaction. Two (2) disbursements totaling $28,882 were not properly encumbered in accordance with state statute. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance to grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends the County gain an understanding of the grant requirements for this program and implement internal controls to ensure compliance with these grant requirements. Management Response: Chairman of the Board of County Commissioners: I plan to communicate with the Budget Board regarding this finding and have already introduced to the Budget Board, a form guideline called “Payne County Grant Administration Plan” to aid in proper documentation, reporting and proper spending of all grant awards. County Clerk: The Payne County Budget Board has approved and adopted a Federal Funding Checklist as well as Federal Funding guidelines on agreements and awards. The Payne County Clerk’s office also communicates with each department and requests that they report to our office any Federal Grants and Awards they receive and report those on their SEFA annually to our office. We also communicate with the Treasurer’s office and request to know when any Federal money has been received. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (8. Procurement, Suspension & Debarment.) reads as follows: Recipients are responsible for ensuring that any procurement using SLFRF funds, or payments under procurement contracts using such funds, are consistent with the procurement standards set forth in the Uniform Guidance at 2 CFR 200.317 through 2 CFR 200.327, unless stated otherwise by Treasury. As outlined in FAQ 13.15, only a subset of the Uniform Guidance requirements at 2 CFR Part 200 Subpart D (Post Federal AwardRequirements) applies to recipients’ use of funds in the revenue loss eligible use category. The procurement standards set forth in the Uniform Guidance at 2 CRF 200.317 through 2 CRF 200.327 are not included in FAQ 13.15’s list of applicable Subpart D requirements that apply to recipients’ use of funds in the revenue loss eligible use category. The Uniform Guidance establishes in 2 CFR 200.319 that all procurement transactions for property or services must be conducted in a manner providing full and open competition, consistent with standards outlined in 2 CFR 200.320, which allows for non-competitive procurements only in certain circumstances. Recipients must have and use documented procurement procedures that are consistent with the standards outlined in 2 CFR 200.317 through 2 CFR 200.320. In addition, the Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibit recipients from entering into contracts with suspended or debarred parties. The procurement standards outlined in the Uniform Guidance require an infrastructure for competitive bidding and contractor oversight, including maintaining written standards of conduct. Your organization must ensure adherence to all applicable local, State, and federal procurement laws and regulations. Further, 2 CFR § 200.319 Competition (d) reads as follows: The non-Federal entity must have written procedures for procurement transactions.
Criteria: The Association should have in place written procurement standards found in 2 CFR 200.317 through 200.326 of the Uniform Guidance. Condition: The Association does not have written procurement standards that are in accordance with the standards found in 2 CFR 200.317 through 200.326 of the Uniform Guidance. Cause: The Association’s written purchasing policy has not been updated to incorporate the standards found in 2 CFR 200.317 through 200.326 of the Uniform Guidance. Effect: The Association is not in compliance with the procurement standards found in 2 CFR 200.317 through 200.326 of the Uniform Guidance. Recommendation: We recommend the Association update its written purchasing policy to ensure the procurement standards found in 2 CFR 200.317 through 200.326 of the Uniform Guidance are incorporated. Management’s Response: The Association will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.
Criteria: 2024 Compliance Supplement stated that the non-federal entity must meet the general procurement standards in 2 CFR section 200.318(a), which indicated that the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. Condition/Context: As a result of our audit procedures, we noted that Eden's current purchasing (procurement) policy does not include the elements required by the Uniform Guidance. In particular, the policy should address the procurement methods outlined in the procurement claw (i.e. micro-purchases, small purchases, competitive bidding, etc.). Repeat Finding from Prior Year(s): No Cause and Effect: This issue arose from Eden’s limited understanding of the Uniform Guidance’s procurement requirements, which contributed to non-compliance with program requirements. Questioned Cost: None Recommendation: We recommend that management revisit its procurement policies to incorporate the necessary elements required by the Uniform Guidance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding that the agency did not have policies for Procurement or Suspension and Debarment. The agency intends to adopt a procurement policy and procedures that meets the general procurement standards in 2 CFR section 200.318(a) and the State of California. The agency is also creating policies and procedures to ensure vendors are not suspended or debarred from work on federally funded projects.
FINDING REFERENCE NUMBER 2024-009 FEDERAL PROGRAMS (ALN – 84.027) SPECIAL EDUCATION – GRANTS TO STATES (IDEA, PART B) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.173) SPECIAL EDUCATION – PRESCHOOL GRANTS (IDEA PRESCHOOL) – SPECIAL EDUCATION CLUSTER (IDEA) (ALN – 84.938A) HURRICANE EDUCATION RECOVERY – INMMEDIATE AID TO RESTART SCHOOL OPERATIONS (RESTART) U.S. DEPARTMENT OF EDUCATION AWARD NUMBERS H027A220003 (07/01/2022 – 09/30/2023); H027A230003 (07/01/2023 – 09/30/2024); H173A220003 (07/01/2022 – 09/30/2023); H173A230003 (07/01/2023 – 09/30/2024); S938A180002 (04/26/2018 – 09/30/2025). COMPLIANCE REQUIREMENT PROCUREMENT AND SUSPENSION AND DEBARMENT TYPE OF FINDING MATERIAL NONCOMPLIANCE AND MATERIAL WEAKNESS CRITERIA 2 CFR Section 200.317, establishes that when conducting procurement transactions under a Federal award, a State or Indian Tribe must follow the same policies and procedures it uses for procurements with non-Federal funds. 2 CFR §200.318(a)(i) establishes that the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. The recipient or subrecipient 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. STATEMENT OF CONDITION For the ALN 84.938A Restart program, we selected the same sample determined to audit the compliance requirement activities allowed or unallowed/allowable costs/cost principle of forty (40) disbursements from a population of six hundred eighty-three (683) disbursements to suppliers made during the fiscal year 2023-2024. For these forty (40) disbursements, we evaluated the procurement process, and we found the following deficiencies: For nineteen (19) of the cases, the PRDE did not provide either all the necessary documentation or, in some instances, only partial information, preventing a proper assessment of the procurement process for each authorized disbursement. In relation to the IDEA Cluster Program (ALNs 84.027 and 84.173), we requested a list of all procurement procedures performed related to professional services and direct services to participants. No information was provided related to procurement procedures. In addition, we selected a sample of twenty-five (25) transactions for which a quotation process should have been performed, no evidence of quotation process was provided. This represents a scope limitation. QUESTIONED COSTS None. PERSPECTIVE INFORMATION After we requested all the supporting information related to procurement processes, the PRDE was not be able to provide the basic documentation for the procurement performed during the reasonable period of time. STATEMENT OF CAUSE In relation to the IDEA Cluster, the program performs a procurement process related to specific services for which no evidence of the procurement performed was provided. In addition, quotations for some purchases are performed through the Purchase Department of the PRDE. Evidence of the sample selection was not provided for evaluation For the ALN 84.938A, due to the lack of an adequate archiving process for the documentation of the procurement processes, the evidence could not be provided for our evaluation POSSIBLE ASSERTED EFFECT Due to the lack of filing documentation related to the procurements performed program ALN 84.938A Restart, we were unable to properly ascertain if compliance with the procurement process was performed. In relation to the IDEA Cluster, we were unable to ascertain compliance with the procurement compliance requirements. IDENTIFICATION OF REPEAT FINDING This is a repeat finding (Finding Reference Number 2023-007). RECOMMENDATIONS We recommend that the PRDE review its internal control procedures for filings to ensure that all procurement documentation is readily available to any auditor or entity tasked with assessing the procurement process. VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding. The Puerto Rico Department of Education (PRDE) acknowledges that the requested procurement documentation was not fully available at the time of the auditors’ review. However, management made every effort to gather and reconstruct the information for all the selected transactions, and the complete documentation will be available. Furthermore, the PRDE is taking actions to improve the accessibility and organization of procurement files to ensure that all documentation is readily available for review in a timely manner. Internal controls over document retention and filing procedures are being reinforced to prevent recurrence of this situation. It is important to note that the procurement processes followed by the PRDE comply with the applicable requirements established under the Code of Federal Regulations (2 CFR Part 200 – Uniform Guidance). Management remains committed to strengthening its internal controls, ensuring full compliance with federal and state requirements, and maintaining complete and timely documentation to support all procurement activities. IMPLEMENTATION DATE Current Fiscal Year. RESPONSIBLE PERSON María de los A. Lizardi Valdés Office of Federal Affairs Director Edgar Delgado Serrano Office of Federal Affairs Associate Director
2 CFR § 1000.10 gives regulatory effect to the Department of Treasury for 2 CFR § 200.320 that states that the non-Federal entity must have and use documented procurement procedures, consistent with the standards of 2 CFR § 200.317 - 200.320. Furthermore, 2 CFR 200.§ 320(a)(2) states that "small purchases are the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity." 31 CFR 19.305 states that Non-Federal entities may not enter into a covered transaction with an excluded person, unless the Department of the Treasury grants an exception under 31 CFR § 19.120. 31 CFR 19.200 identifies “covered transactions” as nonprocurement or procurement transactions subject to the prohibitions of 31 CFR Part 19 which is either at the primary tier, between a Federal agency and a person, or at a lower tier, between a participant in a covered transaction and another person. 31 CFR 19.220 indicates that procurement contracts for goods or services awarded by a participant in a nonprocurement transaction are covered transactions if the amount of the contract is expected to equal or exceed $25,000 or meets certain other specified criteria outlined in 31 CFR § 19.220. All nonprocurement transactions, irrespective of award amount, are considered covered transactions, unless exempt by 31 CFR 19.215. 31 CFR 19.300 provide that when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not excluded or disqualified. This verification may be accomplished by checking the System for Award Management (SAM) exclusions (https://sam.gov), collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity. The District has an established procurement policy and procedures manual, DJF-R, Purchasing Procedures, which states that for purchases above the micro purchases threshold of $10,000 and below the simplified acquisition threshold of $250,000, the District must obtain price rates or quotes from a minimum of two vendors or providers. The District Policy also states that no purchase will be made with federal funds unless the District verifies that the contractor is not suspended or debarred. Additionally, the District is responsible for checking the Ohio Auditor of State website, pursuant to Ohio Revised Code § 9.24 for certified unresolved findings of recovery for any sub-award or contract exceeding $25,000, or when the aggregate amount provided under multiple contracts with a single person or entity during the preceding fiscal year exceeded $50,000 and shall also confirm that the supplier is not debarred or suspended by doing one of the following: (i) checking the Federal government's SAM, which maintains a list of such debarred or suspended suppliers at www.sam.gov; (ii) collecting a certification from the supplier; or (iii) adding a clause or condition to the covered transaction with that supplier. The District did not have proper internal controls in place to document procurement procedures or to verify that all entities with whom the District had entered into covered transactions had not been suspended or debarred. During testing of the AL #21.027 Coronavirus State and Local Fiscal Recovery Funds program, we noted the District could not provide documentation supporting that rates or quotes were obtained from an appropriate number of vendors or providers for all three small purchase contracts reviewed. Additionally, we noted no evidence the District checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor for two out of three small purchase contracts that exceeded $25,000. The above-listed noncompliance also resulted in a qualified opinion over the AL #21.027 Coronavirus State and Local Fiscal Recovery Funds program. Failure to follow the applicable federal procurement, suspension & debarment requirements could result in unallowable purchases, misuse of public funds, questioned costs related to federal monies, or vendors receiving federal funds that are suspended or debarred. The District should implement internal control procedures to ensure they are following the established District policy as well as the federal procurement requirements for small purchases. Additionally, prior to entering into a contract for covered transactions, the District should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
The Ohio County Fiscal Court failed to publicly advertise for bids for all but two of the work site projects for the Emergency Watershed Protection Program project. While the county advertised a pre-bid meeting in the local newspaper for prospective companies to get an opportunity to learn about the project, the actual request for bids should have also been advertised in the local newspaper to ensure fair and cost effective procurement procedures. The total of the amount paid for services not properly advertised was $555,000. A total of $766,100 was spent for this program in the audit year. Per the emergency management staff, this was likely due to a misunderstanding and oversight of what was advertised. They had maintained documentation of the pre-bid meeting being advertised and thought that the actual bid request was advertised as well, but it appears it was not. By not following proper bidding procedures, the public was not made aware of the request for bids for this project and did not have an opportunity to apply to provide services for the project. Only those who attended the pre-bid meeting knew of the bidding procedures and the specifications for the projects. KRS 46.010(2) requires, “each county treasurer, and each county officer who receives or disburses state funds, to keep an accurate account of receipts and disbursements, showing a daily balance of receipts and disbursements.” KRS 46.010(3) requires, “all county officers handling state funds, other than taxes, to make an annual report to the Department for Local Government showing receipts and disbursements, and to make other financial statements as the Department for Local Government requires.” Strong internal controls require management to monitor disbursements to ensure compliance with procurement laws, and to keep good records of all bids and other procurement transactions. KRS 424.260 requires that all contractual services other than professional involving expenditures of greater than $40,000 to be advertised in the local newspaper for bids. In addition, 2 CFR section 200.318 (a) states “The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327." Repeat Finding: This is not a repeat finding from the previous year.
FINDING 2024-203 The Commission is not following Idaho Administrative Rules for Purchasing as required for compliance with the requirements applicable to the Rehabilitation Services-Vocational Rehabilitation Grants to States program. Type of Finding: Material Weakness, Material Noncompliance Assistance Listing Title: Rehabilitation Services - Vocational Rehabilitation Grants to States Assistance Listing Number: 84.126 Federal Award Number: H126A220017, H126A230017, H126A240017 Program Year: October 1, 2021 – September 30, 2023, October 1, 2022 – September 30, 2024, October 1, 2023 – September 30, 2024 Federal Agency: U.S. Department of Education, Rehabilitation Services Administration Compliance Requirement: Procurement, and Suspension and Debarment Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR) contains guidance that nonfederal entities must follow as a condition of receiving federal awards. This guidance in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award. The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include approvals, authorizations, verifications, reconciliations, and segregation of duties. The CFR procurement standards at 2 CFR 200.317 state that, when procuring property and services under a federal award, a state must follow the same policies and procedures it uses for procurements from its nonfederal funds. The state of Idaho purchasing rules within the Idaho Administrative Procedures Act (IDAPA) contain the following provisions: IDAPA 38.05.01.32. Total Cost: The acquisition cost of property, including all components, options, and add-ons available under the contract, related services, and, in the case of ongoing services, the cost of the full term of the contract, including all authorized renewals. Unless a different total term is provided in the contract, the term used for purposes of total cost is five (5) years. IDAPA 38.05.01.041. Acquisition Procedures: • Small Purchases: Services with less than $25,000 total cost; software with less than $15,000 total cost; property with less than $15,000 total cost; a mix of property and services less than $15,000. o Small purchases do not require acquisition through competitive solicitation. Agencies must comply with the division’s small purchase policy. Property available under single agency or open contracts shall be purchased under such contracts and are not a small purchase under this rule unless otherwise authorized by the administrator. • Informal Purchases: Acquisition of property with a total cost exceeding the dollar limits established in this rule for a small purchase and less than the formal sealed procedure limit are informal purchases. o Informal Purchases may be made using: An informal solicitation issued through e-procurement, unless exempted by the administrator; or The formal sealed procedure, when the purchasing authority makes a written determination that using a formal solicitation is in the best interest of the state, including where selection based solely on cost is not appropriate. o Agencies procuring property under this rule shall maintain a purchasing file containing: The solicitation document posted and quotes received. If the acquisition was not publicly posted, the agency shall include a statement describing the justification for determining that posting was impractical or impossible, along with the administrator’s authorization. If not using e-procurement, the agency shall document the quotes received (or its attempt to obtain quotes) from at least three (3) vendors having a significant Idaho economic presence as defined in Section 67-2349, Idaho Code. • Formal Sealed Procedure: o The sealed procedure limit is one hundred fifty thousand dollars ($150,000). o Purchases of property in excess of the sealed procedure limit are made using the formal sealed procedure, unless exempted by these rules or the administrator. IDAPA 38.05.01.042.01. Exceptions requiring written administrator approval. The administrator may exempt the following purchases from the requirement for competitive solicitation by issuing a written determination to the purchasing authority. • Rehabilitation Agency Acquisitions. Acquisitions of property that is provided by non-profit corporations and public agencies operating rehabilitation facilities serving the handicapped and disadvantaged and that is offered for sale at fair market price as determined by the administrator in accordance with these rules. The buyer must submit a written request to the administrator to purchase from a rehabilitation agency and a written approval from the administrator. The purchase must comply with the division’s policy for rehabilitation agency acquisitions. Condition: We identified two vendors that the Commission paid more than $25,000 in total expenditures in fiscal year 2024 and would be subject to compliance with procurement requirements. We tested payments to those vendors for compliance with procurement policies and found that the Commission could not provide documentation to show that State procurement policies were followed. Cause: The Commission erroneously believed that the exemption for rehabilitation agencies applied to more vendors than just not-for-profit entities and public agencies. The Commission also believed that the State purchasing policies did not apply to vendors with many small purchases that are individually below, but collectively exceed, the purchasing thresholds. The Commission has control procedures in place to ensure that grant expenditures are for allowable activities and costs at the transactional level but did not have control procedures to ensure that State procurement rules were followed. Effect: The State’s purchasing policies are designed to ensure that State and federal funds are expended efficiently to meet the goals of State and federal programs. By not following these policies, the Commission could be overpaying for products and services. Recommendation: We recommend that the Commission design and implement procedures to ensure that State purchasing policies are followed. We further recommend that the Commission design and implement procedures to ensure that appropriate documentation is retained to demonstrate compliance and internal controls were operating as intended. Management’s View: Agree - ICBVI acknowledges the failure to document compliance with state procurement policies for select vendors. Corrective Action: • Policy Clarification: ICBVI will ensure future purchases above the threshold are fully documented in accordance with state requirements. • Procedural Update: A procurement checklist and documentation template will be added to internal controls to support purchases subject to state policy. We have a training setup with DOP on 12/18/25 to help with correcting this deficiency. Upon completion of this training, we will conduct comprehensive internal training for all ICBVI staff to ensure consistent understanding and compliance with state procurement requirements. Auditor’s Concluding Remarks: We thank the Commission for its cooperation and assistance throughout the audit.
FINDING 2024-240 The Division is not following Idaho Administrative Rules for Purchasing as required by federal requirements. Type of Finding: Material Weakness, Material Noncompliance Assistance Listing Title: Rehabilitation Services – Vocational Rehabilitation Grants to States Assistance Listing Number: 84.126 Federal Award Number: H126A240016, H126A220016, H126A210016 Program Year: October 1, 2020 – September 30, 2022; October 1, 2021 – September 30, 2023; October 1, 2023 – September 30, 2024 Federal Agency: U.S. Department of Education, Rehabilitation Services Administration Compliance Requirement: Procurement and Suspension and Debarment Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR) contains guidance that nonfederal entities must follow as a condition of receiving federal awards. This guidance in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award. The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include approvals, authorizations, verifications, reconciliations, and segregation of duties. The CFR procurement standards at 2 CFR 200.317 states that, when procuring property and services under a federal award, a state must follow the same policies and procedures it uses for procurements from its nonfederal funds. The state of Idaho purchasing rules within the Idaho Administrative Procedures Act (IDAPA) contain the following provisions: IDAPA 38.05.01.32. Total Cost: The acquisition cost of property, including all components, options, and add-ons available under the contract, related services, and, in the case of ongoing services, the cost of the full term of the contract, including all authorized renewals. Unless a different total term is provided in the contract, the term used for purposes of total cost is five (5) years. IDAPA 38.05.01.041. Acquisition Procedures: • Small Purchases: Services with less than $25,000 total cost; software with less than $15,000 total cost; property with less than $15,000 total cost; a mix of property and services less than $15,000. o Small purchases do not require acquisition through competitive solicitation. Agencies must comply with the division’s small purchase policy. Property available under single agency or open contracts shall be purchased under such contracts and are not a small purchase under this rule unless otherwise authorized by the administrator. • Informal Purchases: Acquisition of property with a total cost exceeding the dollar limits established in this rule for a small purchase and less than the formal sealed procedure limit are informal purchases. o Informal Purchases may be made using: An informal solicitation issued through e-procurement, unless exempted by the administrator; or The formal sealed procedure, when the purchasing authority makes a written determination that using a formal solicitation is in the best interest of the state, including where selection based solely on cost is not appropriate. o Agencies procuring property under this rule shall maintain a purchasing file containing: The solicitation document posted and quotes received. If the acquisition was not publicly posted, the agency shall include a statement describing the justification for determining that posting was impractical or impossible, along with the administrator’s authorization. If not using e-procurement, the agency shall document the quotes received (or its attempt to obtain quotes) from at least three (3) vendors having a significant Idaho economic presence as defined in Section 67-2349, Idaho Code. • Formal Sealed Procedure: o The sealed procedure limit is one hundred fifty thousand dollars ($150,000). o Purchases of property in excess of the sealed procedure limit are made using the formal sealed procedure, unless exempted by these rules or the administrator. IDAPA 38.05.01.042.01. Exceptions requiring written administrator approval. The administrator may exempt the following purchases from the requirement for competitive solicitation by issuing a written determination to the purchasing authority. • Rehabilitation Agency Acquisitions. Acquisitions of property that is provided by non-profit corporations and public agencies operating rehabilitation facilities serving the handicapped and disadvantaged and that is offered for sale at fair market price as determined by the administrator in accordance with these rules. The buyer must submit a written request to the administrator to purchase from a rehabilitation agency and a written approval from the administrator. The purchase must comply with the division’s policy for rehabilitation agency acquisitions. Condition: We identified a population of 75 vendors that were paid more than $25,000 in fiscal year 2024 by the Division. The total dollar value of that population is $7,366,145 and we also identified 18 vendors within that population that received total payments that were large enough to be considered individually significant, based on materiality. We reviewed all of those 18 vendors and also selected a random sample of 6 vendors from the remaining 57 vendors in our population to arrive at a total testing group of 24 vendors. We evaluated if the Division’s internal controls were properly designed, in place, and effective in preventing or detecting errors. We also assessed if the Division was in compliance with procurement policies, both as required by the Rehabilitation Services – Vocational Rehabilitation Grants to States program and the State. The main internal control that the Division relies on to ensure compliance is that appropriate personnel review the procurement documents and approve the contract or purchase made prior to payment. The Division could not provide evidence that the review and approval occurred for 3 of the 6 (or 50 percent) randomly sampled vendors, and for 2 of the 18 (or 11 percent) vendors that had significant payments. We also found that the Division could not provide documentation to show that State procurement policies were followed for 4 of the 6 (or 67 percent) sampled vendors and 4 of the 18 (or 22 percent) individually significant vendors. Cause: The Division misunderstood several purchasing requirements. It believed that an exemption for rehabilitation agencies applied to more vendors than just not-for-profit entities and public agencies. The Division also believed that the State purchasing policies did not apply to vendors with many small purchases that are individually below, but collectively exceed, the purchasing thresholds. This misunderstanding led to noncompliance with purchasing requirements. Effect: The State’s purchasing policies are designed to ensure that State and federal funds are expended efficiently to meet the goals of State and federal programs. By not following these policies, the Division could be overpaying for products and services and is not in compliance with federal grant requirements. Recommendation: We recommend that the Division design and implement procedures to ensure that State purchasing policies are followed. This should include training to ensure that staff understand what purchases require additional procedures. We further recommend that the Division design and implement procedures to ensure that appropriate documentation is retained to demonstrate compliance and that internal controls were operating as intended. Management’s View: The Division will ensure full compliance with Idaho Administrative Rules for Purchasing and applicable federal procurement standards by developing, implementing, and maintaining internal controls, procedures, and documentation of practices that verify all procurements, regardless of funding source or transaction size adhere to State and Federal purchasing requirements. Corrective Action: 4.1 Policy Alignment: Review and revise internal procurement policies and procedures to align with IDAPA 38.05.01, 2 CFR 200.317, and 2 CFR 200.303 requirements. 4.2 Training and Awareness: Provide training to all staff to ensure understanding of: 4.2.1 Purchasing thresholds and categories (small, informal, and formal purchases). 4.2.2 Documentation and approval requirements. 4.2.3 Process and documentation requirements for purchases requiring exemptions. 4.3 Internal Control Strengthening: Develop and implement internal control mechanisms to ensure compliance with State and Federal purchasing requirements. 4.4 Monitoring and Accountability: Establish a quality assurance and compliance monitoring process to perform monitoring of procurement transactions to verify compliance with Division policies and procedures. Auditor’s Concluding Remarks: We thank the Division for its cooperation and assistance throughout the audit.
FINDING 2024-010 Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 21611-045-PN01, 22611-045-PN01, 22611-045-ARP, 21619-045-PN01, 22619-045-PN01, 22619-045-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation had not properly designed or 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 related to the Procurement and Suspension and Debarment compliance requirement. Procurement - Small Purchases Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a nonfederal entity. As Indiana Code has set a more restrictive threshold of $150,000, the informal procurement method is permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. The population for those procurements that fell within the small purchase range consisted of three vendors with a total purchased amount from those vendors of $75,284. The School Corporation did not provide adequate documentation detailing the history of procurement, which must include the reason for the procurement method used, for all three vendors. Suspension and Debarment 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 and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAM exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. One vendor provided contracted services paid with Special Education Grant funds during the audit period totaling $44,827. Upon inquiry of the School Corporation, it was determined that the School Corporation did not verify that the contractor was not suspended, debarred, or otherwise excluded. INDIANA STATE BOARD OF ACCOUNTS 36 NORTH LAWRENCE COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The lack of effective internal controls and noncompliance were systemic issues 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). . . ." 2 CFR 200.318 states in part: "(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 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases— (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . ." INDIANA STATE BOARD OF ACCOUNTS 37 NORTH LAWRENCE COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Indiana Code 5-22-8-3 states in part: "(a) . . . if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) . . . the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." 2 CFR 180.300 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 intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to affect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, procurement procedures for goods and services were not adhered to, and vendors to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. INDIANA STATE BOARD OF ACCOUNTS 38 NORTH LAWRENCE COMMUNITY SCHOOLS SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Condition Upon inquiry of county personnel and a test of four (4) disbursements totaling $452,184, the following instances of noncompliance were noted: • The County failed to document suspension and debarment of vendors for purchases over $25,000. • The County failed to have written standards of conduct that cover conflicts of interest and that govern the performance of its employees engaged in the selection, award, and administration of contract. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal disbursements are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with grant requirements and could result in a loss of federal funds. Recommendation: OSAI recommends the County gain an understanding of the grant requirements for this program and implement internal controls to ensure compliance with these grant requirements. Management Response: Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in Office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (8. Procurement, Suspension & Debarment.) reads as follows: Recipients are responsible for ensuring that any procurement using SLFRF funds, or payments under procurement contracts using such funds, are consistent with the procurement standards set forth in the Uniform Guidance at 2 CFR 200.317 through 2 CFR 200.327, unless stated otherwise by Treasury. As outlined in FAQ 13.15, only a subset of the Uniform Guidance requirements at 2 CFR Part 200 Subpart D (Post Federal Award Requirements) applies to recipients’ use of funds in the revenue loss eligible use category. The procurement standards set forth in the Uniform Guidance at 2 CRF 200.317 through 2 CRF 200.327 are not included in FAQ 13.15’s list of applicable Subpart D requirements that apply to recipients’ use of funds in the revenue loss eligible use category. The Uniform Guidance establishes in 2 CFR 200.319 that all procurement transactions for property or services must be conducted in a manner providing full and open competition, consistent with standards outlined in 2 CFR 200.320, which allows for non-competitive procurements only in certain circumstances. Recipients must have and use documented procurement procedures that are consistent with the standards outlined in 2 CFR 200.317 through 2 CFR 200.320. In addition, the Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibit recipients from entering into contracts with suspended or debarred parties. The procurement standards outlined in the Uniform Guidance require an infrastructure for competitive bidding and contractor oversight, including maintaining written standards of conduct. Your organization must ensure adherence to all applicable local, State, and federal procurement laws and regulations. Further, 2 CFR § 200.319 Competition (d) reads as follows: The non-Federal entity must have written procedures for procurement transactions.
Finding 2024-005 – Inadequate Procurement Documentation (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the InteriorFederal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Federal procurement standards require non-Federal entities to maintain records sufficient to detail the history of procurement, including the method of procurement, selection of contract type, contractor selection or rejection, and basis for the contract price. Competitive procurement must follow the entity’s written procedures consistent with 2 CFR §§200.317-200.327, including: Written procedures for procurement (§200.318(a)). Full and open competition requirements (§200.319). Methods of procurement (sealed bids, proposal requirements, and required documentation (§200.320). Contract cost and price justification, (§200.324). Suspension/debarment verification for covered transactions (§200.214; §200.213). Condition: During the audit period, the Entity did not retain sufficient procurement documentation for several contracts funded under the above Assistance Listings. Specifically, files lacked one or more of the following: Evidence of the procurement method used. Price or cost analysis. Suspension/debarment checks for vendors where required. Documentation of competition. Conflict-of-interest attestations. Cause: Partnership for the Umpqua Rivers procurement procedures were not sufficiently detailed or consistently applied to federal purchases. No evidence of procedures or review for procurement or suspension / debarment was provided to auditors. Turnover and limited training on Uniform Guidance procurement standards contributed to the inconsistent file completeness. Effect or Potential Effect: Without complete procurement documentation, the Entity cannot demonstrate compliance with federal procurement requirements, increasing the risk of: Noncompetitive awards or unreasonable prices. Unallowable costs for the award requirements. Potential disallowance or repayment of federal funds. Findings in federal or pass-through monitoring and future audits. Questioned Cost: Yes, $902,496 related to expenditures that had no procurement support or detail. Context: During our audit, it was found that the Partnership for the Umpqua Rivers had experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to procurement, suspension or debarment procedures or processes. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers: Update Written Procurement Procedures o Incorporate Uniform Guidance thresholds and methods (§200.320), competition requirements (§200.319), and documentation expectations (history of procurement). o Embed steps for suspension / debarment checks and Appendix II Contract clauses. Standardized Procurement Checklist o Pre-award checklist that verifies: method, competition evidence, cost/price analysis, conflict of interest attestations, SAM exclusion check, and required federal clauses. o Post -award checklist ensuring complete contract file (award memo, bid tab / evaluation, signed agreement, clause verification). Cost/Price Analysis Guidance o Require documented price reasonableness for small purchases, formal cost or price analysis for larger or sole-source awards, per (§200.324). Training & Accountability o Provide targeted training to procurement and program staff on 2 CFR §§200.317- 20.327 and Assistance Listing award conditions. o Implement supervisory pre-award review and periodic file audits. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager
2024-003 Documented Procurement Policy Federal Program - U.S. Department of the Treasury – Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Federal Award Number - SLFRP0136 Compliance Requirement - Procurement, Suspension, and Debarment Repeat Finding - This is a repeat finding of 2023-003. Corrective action was not completed prior to or during the audit period due to the timing of audit completion and recommendations to management. Criteria - Per 2 C.F.R. § 200.318(a), non-federal entities must use documented procurement procedures that reflect applicable state and local laws and regulations and conform to applicable federal laws and the procurement standards identified in the Uniform Guidance, including those set forth in §§ 200.317 through 200.327. Condition - During our audit, we noted that the Organization did not have a documented procurement policy in place that complies with the Uniform Guidance. Cause - The Organization has historically had a low volume of procurement activity and has not formalized written procurement procedures. Effect - Without a documented procurement policy, there is an increased risk that future procurements may not comply with applicable federal requirements, which could result in unallowable costs or other compliance issues. Questioned Costs - None noted. Context - This condition was identified during our testing of internal controls over compliance for the Procurement, Suspension, and Debarment requirement. Although the Organization did not enter into any contracts or purchases during the audit period that exceeded the micro-purchase threshold, the absence of a required policy represents a significant deficiency in internal control over compliance. Recommendation - We recommend that the Organization develop and implement a written procurement policy that complies with 2 C.F.R. §§ 200.318–.327 and ensure that staff are trained on its provisions. View of Responsible Officials - We agree with the finding. The organization lacked a formal procurement policy that was effective for the fiscal year ended June 30, 2024. A procurement policy which included all required elements was drafted and implemented with an effective date of July 1, 2025.
2024-005 - Procurement and Suspension, and Debarment – Internal Control and Compliance over Procurement and Verification Against the System for Award Management (“SAM”) Identification of the Federal Program: Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: N/A Assistance Listing Number: 97.044 Assistance Listing Title: Assistance to Firefighters Grant Federal Agency: Department of Homeland Security Pass-Through Entity: N/A Federal Award Identification Number: EMW-2020-FG-15445, EMW-2021-FG-00268 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Suspension and Debarment, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a nonprocurement 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. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Pursuant to 2 CFR 200.318 of the Uniform Guidance, the City is required to comply with the procurement standards, when using federal funds. These standards require non‑federal entities to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR 200.317 through 2 CFR 200.327. The City’s purchasing policies require that all purchases charged to the City have an authorized Purchase Order (PO) in place before an order is placed or goods are received. The policy states that if an individual attempts to make a purchase without a City PO number, the vendor must request an authorized PO number and the name and department of the individual. The purchase order number is essential for conducting business with the City and ensures proper authorization, documentation, and payment. Therefore, all transactions including orders of goods or materials regardless of cost or type must be supported by a valid, approved PO prior to purchase activity. Condition: Coronavirus State and Local Fiscal Recovery Funds (ARPA) During our audit, we noted that eleven (11) out of thirty seven (37) suspension and debarment samples tested, the City did not have documentation on verifying the vendors against the SAM to ensure that they were not suspended or debarred from federally funded purchases. We also noted that thirty one (31) out of thirty seven (37) procurement samples tested, the City didn’t have purchase orders for these samples. Assistance to Firefighters Grant During our audit, we noted that two (2) out of two (2) procurement samples tested, the City did not have documentation on verifying the vendors against the SAM to ensure that they were not suspended or debarred from federally funded purchases. Cause: The City did not have a consistent process in place to ensure that the procurement process have been followed and maintained, and to require staff maintain the proof of verification performed on checking the suspension or debarment over vendors that the City makes contracts with federally-funded projects. Effect or Potential Effect: The lack of purchase orders limits transparency into procurement process, approval, and authorization, and weakens internal controls over spending. Without verifying whether vendors are suspended or debarred from working on federally-funded projects, the City could be contracting with vendors that are prohibited from working on federally-funded projects. Questioned Costs: None. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City establish internal control procedures to monitor compliance requirements to ensure the procurement process is implemented and monitored, and vendors are not suspended or debarred from federallyfunded purchases. Views of Responsible Officials: Management concurs with the finding.
MATERIAL WEAKNESS Finding Number: 2024-003 Material Weakness in Internal Control over Compliance Federal Program: 84.027 & 84.173 Special Education Cluster (IDEA) Federal Program: 84.425D/84.425U Education Stabilization Fund Criteria: 2 CFR §200.318(a) requires non-federal entities to establish and maintain effective internal control over procurement transactions to ensure compliance with applicable federal statutes and regulations. 2 CFR §§200.317–200.327 require non-federal entities to maintain written procurement policies and procedures that address procurement methods, documentation requirements, and contract administration. 2 CFR §200.430(i) requires charges to federal awards for salaries and wages to be supported by documentation that accurately reflects the work performed and supports the allowability and allocation of payroll costs.2 CFR §200.302(b)(3) requires financial management systems to maintain records that adequately identify the source and application of funds for federally funded activities. Condition: The entity did not maintain adequate internal controls over procurement and payroll expenditures charged to the federal program. Specifically: • The entity does not have a formally adopted, written procurement policy that complies with federal procurement requirements. • Invoices tested did not include supporting documentation such as purchase orders, executed contracts, or memoranda of understanding (MOUs) to substantiate the procurement of goods or services, approval of the transactions, or the basis for the costs incurred. • Payroll expenditures charged to the federal program lacked sufficient supporting documentation, including employment contracts or documentation identifying the employee’s placement on the applicable salary chart within the Teacher and Support Staff Association agreement. • As a result, the entity was unable to demonstrate that payroll costs were calculated in accordance with approved pay rates and were allowable and properly supported. Cause: The deficiencies resulted from the absence of formal procurement policies and insufficient internal controls over documentation standards and record retention for procurement and payroll transactions. Effect: Due to the lack of written procurement policies and insufficient supporting documentation for procurement and payroll expenditures, the entity is unable to demonstrate compliance with federal procurement and cost principles. These deficiencies increase the risk that unallowable or improperly supported costs could be charged to the federal program and not be detected in a timely manner. Identification of Questioned Costs:None identified. Context: The absence of formal procurement policies and consistent supporting documentation limited the ability to readily demonstrate compliance with federal procurement and cost principles and increased the extent of audit procedures required. Repeat Finding: This is a repeat finding of 2023-03.Recommendation: We recommend that management update its procurement policy to include all current requirements under 2 CFR 200 and implement a process to periodically review and revise the policy to remain compliant with future federal regulation changes. Require that all procurement transactions be supported by purchase orders, executed contracts, MOUs, invoices, and evidence of approval and receipt. Ensure payroll expenditures charged to federal programs are supported by employment contracts and documentation identifying employee placement on the applicable salary schedule in accordance with collective bargaining agreements, as required by 2 CFR §200.430. Implement monitoring and training procedures to ensure consistent compliance with federal documentation requirements. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the entity.
Criteria: The Uniform Guidance 2 CFR Part 200.318 require that the Agency have documented procurement procedures for procurement transactions under a Federal award or subaward Condition: The Agency has a procurement policy in place; however, it is not fully aligned with the procurement standards set forth in 2 CFR Part 200.317–200.327 of the Uniform Guidance. Specifically, the policy does not incorporate all required procurement methods or procedures, such as competitive bidding (sealed bids), even though no purchases during the audit period met the threshold requiring formal bidding. Cause: The Agency's current policy has not been updated to fully address the specific requirements of 2 CFR Part 200.317–200.327 of the Uniform Guidance. Effect: The Agency is not in compliance with 2 CFR Part 200.317–200.327 of the Uniform Guidance. Questioned Costs: None reported. Context: Not applicable. Repeat Finding: Not applicable. Recommendation: Although there were no purchases in the audit period meeting the threshold for competitive bidding, we recommend that the Agency review and revise its procurement policy to ensure compliance. This should include procedures for all procurement methods including sealed bids. View of Responsible Officials: See management’s corrective action plan.
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-through Agency: Northampton County Pass-Through Number: N/A Award Period: May 18, 2022 - December 31, 2025; October 1, 2022 - December 31, 2025 May 18, 2023 - December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: Uniform Guidance (2 CFR §§ 200.317–200.327) requires non‑federal entities to maintain written procurement procedures and documentation supporting procurement transactions to ensure compliance with applicable federal regulations. Additionally, entities must verify and document that vendors are not suspended or debarred from participation in federal programs prior to award, in accordance with 2 CFR § 200.214. Condition: During audit testing of procurement and suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to provide documentation supporting the procurement selections tested. Additionally, documentation evidencing verification of vendor suspension and debarment status was not available for the selections reviewed. Questioned Costs: None. Context: Procurement and suspension and debarment documentation was requested for audit testing, and management was unable to provide documentation supporting the procurement selections and vendor eligibility for the items tested. Cause: The Organization did not consistently maintain required procurement and suspension and debarment documentation. Contributing factors included turnover within the finance and administrative functions and the absence of formalized procedures to ensure documentation is retained and readily available for audit and monitoring purposes. Effect: The lack of procurement and suspension and debarment documentation constitutes noncompliance with federal procurement requirements. Without adequate documentation, the Organization cannot demonstrate that procurements were conducted in accordance with Uniform Guidance or that vendors were eligible to receive federal funds and increases the risk of improper or unsupported expenditures of federal funds. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should strengthen internal controls over procurement and suspension and debarment compliance by establishing and enforcing written procedures requiring documentation of procurement methods, vendor selection, and verification of suspension and debarment status prior to award. Management should ensure that all required documentation is retained in accordance with federal record retention requirements and subject to supervisory review. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Finding Reference: 2024-006 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Incomplete Federal Requirements within Procurement Policies Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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).” Part 200.320 Methods of procurement to be followed states the following: “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” regarding the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have a procurement policy that conforms to all applicable standards contained in the Uniform Guidance, when purchasing goods or services with the federal funds. Cause The Corporation did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving such federal funds related to their federal programs. Effect or potential effect Purchasing of goods and/or servicing with the major federal programs may not be in compliance with the Uniform Guidance. Questioned costs None. Identification of a repeat finding This is a repeat finding of Finding 2023-001. Context Management has not established a procurement policy in line with the applicable standards contained in the Uniform Guidance based on review of the existing policy and discussions with management, however, no other instances of noncompliance with procurement standards identified in 2 CFR part 200 were noted as the amount of purchases exceeding the micro-purchase threshold was not direct and material to this program and therefore no further testing over procurement was performed. Recommendation The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials There is no disagreement with the audit finding.
2024-003 – Missing Federally Required Procurement Clauses in Vendor Contracts Federal Agency: Department of the Treasury Award Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Year: 2024 Compliance Requirement: Procurement Type of Finding - Compliance Internal Control over Compliance – Other Matter Condition: During our review of procurement documentation for federal grant expenditures, we noted that the Town did not include all required federal procurement contract clauses in its agreements with vendors procured with federal funds. Our review of a contract issued under the State and Local Fiscal Recovery Fund grant, lacked required clauses related to the Contract Work Hours and Safety Standards Act, the Clean Air and Federal Water Pollution Control Acts, Byrd Anti-Lobbying Amendment, domestic preferences for procurements, and the Davis-Bacon Act. Criteria: Per Uniform Guidance 2 CFR 200.317–200.327 and Appendix II to Part 200, all contracts made by non-federal entities under federal awards must contain the applicable provisions described in Appendix II, including but not limited to clauses for termination for cause and convenience, Equal Employment Opportunity, Davis-Bacon Act (if applicable), Clean Air Act, and Byrd Anti-Lobbying Amendment. Cause: The omission appears to have resulted from a lack of comprehensive procedures to ensure all required federal clauses are incorporated into applicable contracts. Effect: Failure to include federally required contract clauses exposes the Town to the risk of noncompliance with federal procurement requirements, which may result in questioned costs, repayment of federal funds, or jeopardized future funding. Recommendation: We recommend that the Town develop and implement procedures to ensure all required federal clauses are included in all vendor contracts funded in whole or in part with federal awards. Staff responsible for procurement should receive training on federal requirements, and contracts should be reviewed for compliance prior to execution. Views of Responsible Officials: The Town is committed to strengthening its procurement practices and ensuring compliance with Uniform Guidance requirements. To address this issue, the Town will develop and implement standardized contract templates, and a comprehensive checklist of required federal clauses applicable to federally funded procurements for any future federal dollars. The Town will formalize procedures to ensure that a secondary review is consistently performed and documented for all required federal reports prior to submission and will designate a member of management or another qualified official to perform and document this review
Finding 2024-016: Material Weakness in Internal Control and Material Noncompliance – Procurement and Suspension and Debarment Assistance Listing Program Title and Number: Special Education (IDEA) Cluster (84.027, 84.173), COVID 19-Coronavirus State & Local Fiscal Recovery Funds (21.027) Federal Agency: U.S. Department of Education, U.S. Department of Treasury Pass-through Entity: State of Connecticut Department of Education, State of Connecticut Department of Emergency Services and Public Protection Award year: 2023 – 2024 Criteria or specific requirement: The City, which includes Danbury Public Schools (DPS), must follow procurement standards set out at 2 CFR sections 200.318 through 200.326. There are three types of procurement methods described in this section: informal procurement methods (for micro-purchases and simplified acquisitions); formal procurement methods (through sealed bids or proposals); and noncompetitive procurement methods. For any of these methods, the recipient or subrecipient must maintain and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319. Additionally, 2 CFR Section 180 requires that recipients of federal awards have policies and procedures in place to verify contracted vendors are not on the federal suspended or debarred parties list. Condition: The DPS Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, DPS did not follow their own procurement policy in certain instances which consists of obtaining three quotes for a small purchase procurements and advertising for bids publicly for large >$5,000 purchase procurements. They only obtained one quote for small purchases, and they did not use a public bid process for expenditures over $5,000. Additionally, DPS did not have internal controls in place to ensure vendor eligibility was verified prior to entering into a covered transaction with them. Cause: While DPS has a formal policy around required bids, the thresholds have not been updated in several years and there was a lack of controls that ensured the DPS procurement policy was being adhered to in order to be compliant with the compliance standards. Finally, the policy did not address verifying vendors were neither suspended nor debarred. Effect: Possible effects include not awarding the purchase to the lowest qualified bidder or to a vendor on the suspended or debarred parties list. Context: For the Coronavirus State and Local Fiscal Recovery Funds program, there was a population of 183 procurements during the audit period. Of these procurements, there were 29 vendors that were subject to the rules on suspension and debarment. Of those 29 vendors, we sampled eight for testing. Two out of eight vendors tested did not have documentation that DPS verified the vendors were not suspended or debarred prior to entering into a covered transaction with them. The total amount of the two was $438,885 out of the total sample of $996,779. We also selected a sample of 23 procurements totaling $2,698,309 for testing. One sample was a small purchase totaling $2,550 which required three quotes however only one quote was obtained. The sample was not intended to be, and was not, a statistically valid sample. For the IDEA Cluster, there was a population of 251 procurements during the audit period. We sampled 31 procurements for testing totaling $659,075. Three of the procurements tested totaling $293,692 did not follow the DPS procurement policy. Two exceptions (totaling $290,722) were for large purchases which did not follow the policy for procurement through a formal bid process. The other exception was a small purchase totaling $2,970 which did not follow the requirement of obtaining three or more quotes. The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: For procurement under the Coronavirus State and Local Fiscal Recovery Program- $2,550 For procurement under the IDEA Cluster- $293,692 Repeat Finding: 2023-007 Recommendation: We recommend DPS implement controls that require review of each procurement to ensure DPS obtained the adequate number of quotes or bids for each expenditure. Additionally, we recommend DPS update their procurement thresholds to be more consistent with the compliance minimum requirements. Finally, we recommend DPS modify their policy to address suspension and debarment requirements to ensure they don’t enter into a covered transaction with a suspended or debarred vendor. The policy should require documentation of the search performed. Views of Responsible Officials: Management agrees with the finding.
The Arizona Department of Education failed to follow State law for $30.2 million of goods and services purchases and risks not receiving the most advantageous prices Assistance Listings number(s) and name(s): 84.425U COVID-19-Education Stabilization Fund-American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER) Award number(s) and year(s): S425U210038-21C March 24, 2021 through September 30, 2026 Federal agency: U.S. Department of Education Compliance requirement(s): Procurement Questioned costs: $13,604,457 Condition The Arizona Department of Education (ADE) and Arizona Department of Administration took appropriate action by reporting to us and the Arizona Attorney General an instance of potential fraud. As part of our review, we determined that contrary to federal regulation, State law, and the Arizona Procurement Code, ADE’s Procurement Division (Division) failed to follow State law and related administrative rules when procuring $30.2 million of goods or services from third-party vendors, of which $13.6 million was spent during fiscal year 2024. Specifically, the Division did not obtain proper approvals and/or prepare written determinations for exceptions to using competitive procurement methods for 7 of 8 vendors we tested as follows: X For 6 vendors, the Division did not obtain approval from the State Procurement Officer to use noncompetitive procurements or prepare written determinations for exceptions to competition when awarding contracts for $27.2 million of goods or services, such as student diagnostic assessments, of which $13.5 million was spent during fiscal year 2024. Specifically, the Division used a Request for Grant Application noncompetitive method, which is used when ADE is seeking to provide financial or other assistance to another entity. X For 1 vendor, the Division issued a noncompetitive waiver to award a contract totaling $3 million without obtaining written approval from the State Procurement Officer. ADE spent nearly $121,000 during fiscal year 2024 with this vendor. Effect The Division’s failure to follow State law and related administrative rules for procuring goods and services increased ADE’s risk of not receiving the most advantageous price for the $37.3 million paid to 57 vendors for goods and services purchased with federal monies during fiscal year 2024, thereby increasing the risk of wasting federal monies. If ADE could have obtained these goods or services at a lower cost, these savings could have been used in other areas to benefit the State and its residents, such as diagnostic and learning loss assessments. Finally, ADE is at risk that this finding applies to other federal programs it administers. Cause The Division reported that it had limited time to obligate monies within the program period. However, we found that ADE had at least 4 months to conduct a competitive solicitation for the goods and services. ADE also reported that because of procurement staff turnover, ADE is unable to justify the procurement decisions reflected in the items we tested. ADE’s policies lacked procedures to obtain approval from the State Procurement Officer and to prepare written determinations for exceptions to using competitive procurement methods, such as noncompetitive waivers, when purchasing goods and services from third-party vendors, as required by the Arizona Procurement Code. Criteria Federal regulation requires ADE to follow the same policies and procedures it uses for nonfederal procurements (2 CFR § 200.317). State law and the Arizona Procurement Code require ADE to conduct all procurements in accordance with established thresholds, methods, and documentation standards, including approval from the State Procurement Officer for noncompetitive procurements, and further require written determinations for exceptions to competition, such as noncompetitive waivers, and that such determinations include sufficient justification, approvals, and supporting documentation.1,2 Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Division 1. Follow federal regulation, State law, and the Arizona Procurement Code for procurements related to federal grant awards. 1 A.R.S. Title 41, Ch. 23, and the Arizona Administrative Code Title 2, Ch. 7, R2-7-101. 2 State of Arizona, Department of Administration Procurement. (2022). Arizona Procurement Code. Retrieved 3/5/2026 from https://spo.az.gov/ sites/default/files/2025-05/Arizona%20Procurement%20Code_11-22_0.pdf 2. Update and implement policies and procedures and responsible employees to use competitive procurement methods or otherwise obtain approval from the State Procurement Officer and to prepare written determinations for exceptions to using competitive procurement methods, such as noncompetitive waivers, when purchasing goods and services from third-party vendors. Views of responsible officials State management concurs with this finding. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials regarding these recommendations. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
DEPARTMENT OF HEALTH PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Material Noncompliance 2024-030 Strengthen Controls to Ensure Compliance with Procurement, Suspension and Debarment Requirements of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) program ALN Number(s) 10.557 - Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Federal Award 215MS707W5003 (10/1/2022 – 9/30/2022) 235MS704W1003 (10/1/2022 – 9/30/2023) 235MS704W1006 (10/1/2022 – 9/30/2023) 235MS704W5003 (10/1/2022 – 9/30/2024) 245MS704W1003 (10/1/2023 – 9/30/2024) 245MS704W1006 (10/1/2023 – 9/30/2024) Questioned Costs N/A Criteria The Code of Federal Regulations (2 CFR 200.317) Procurements by states, when procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-Federal funds. Code of Federal Regulations (2 CFR 200.214) Suspension and Debarment, restricts 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 Code of Federal Regulations (2 CFR 180.300) states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Code of Federal Regulations (2 CFR 200.303(a)), a 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. These internal controls should comply 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). Condition During testwork performed over procurement, suspension and debarment requirements for the special supplemental nutrition program for women, infants, and children (WIC) program as of June 30, 2024, The Department of Health (Department) was unable to provide documentation that it procured goods and services under the program in accordance with its established procurement policy nor that it ensured vendors were not suspended or debarred Cause The Department’s procedures and internal controls were not sufficient to ensure that it procured goods and services under the program in accordance with its established procurement policy nor that it ensured vendors were not suspended or debarred. Effect The Department did not follow its procurement policy, nor did it verify vendors’ suspension and debarment status prior to procuring services from the vendor. Failure to adhere to procurement and suspension and debarment policies and procedures may result in obtaining goods or services under terms that are not in the best interest of the federal program and/or the Department or with vendors who are ineligible to participate in the program. Recommendation We recommend the department review and enhance controls and procedures to ensure that it follows its procurement policy and federal suspension and debarment regulations for all applicable goods and services purchased for the program. Repeat Finding No. Statistically Valid Yes.
DEPARTMENT OF HEALTH PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Material Noncompliance 2024-033 Strengthen Controls to Ensure Compliance with Procurement, Suspension and Debarment Requirements of the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program ALN Number(s) 93.323 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Award NU50CK000550 (8/1/2019 – 7/31/2026) Questioned Costs N/A. Criteria Code of Federal Regulations (2 CFR 200.317), Procurements by states, when procuring property and services under a Federal award, a state must follow the same policies and procedures it uses for procurements from its non-Federal funds. Code of Federal Regulations (2 CFR 200.214), Suspension and Debarment, restricts 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. Coder of Federal Regulations (2 CFR 180.300), states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Code of Federal Regulations (2 CFR 200.303(a)), a 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. These internal controls should comply 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). Condition During testwork performed over procurement, suspension and debarment requirements for the Epidemiology and Laboratory Capacity for Infectious Diseases program as of June 30, 2024, the Department of Health (Department) was unable to provide documentation that it procured goods and services under the program in accordance with established procurement policy nor that it ensured vendors were not suspended or debarred. The auditor noted the following: • For eight of eight contracts selected for testing, the Department was unable to provide documentation that they were issued in accordance with its procurement policy. • For six of six vendors selected for testing, the Department was unable to provide documentation that it had verified the vendors were not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause The Department’s procedures and controls were not sufficient to ensure that program purchases were made in accordance with its established procurement policy nor that suspension and debarment regulations were followed. Effect The Department did not follow its procurement policy, nor did it verify vendors’ suspension and debarment status prior to procuring services from the vendor. Failure to adhere to procurement and suspension and debarment policies and procedures may result in obtaining goods or services under terms that are not in the best interest of the federal program and/or the Department or with vendors who are ineligible to participate in the program. Recommendation We recommend the Department should review and enhance controls and procedures to ensure that it follows its procurement policy and federal suspension and debarment regulations for all applicable goods and services purchased for the program. Repeat Finding No. Statistically Valid Yes.
Condition: Creek County did not have written standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts. Cause of Condition: Policies and procedures have not been designed and implemented to ensure compliance with all federal award requirements. Effect of Condition: This condition resulted in noncompliance with federal grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends county officials and department heads gain an understanding of federal programs awarded to Creek County. Internal control procedures should be designed and implemented to ensure compliance with federal requirements. Management Response: Chairman of the Board of County Commissioners and County Clerk: It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control, and we will review the policy annually, so that all conflicts can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk's Office will work with the District Attorney's Office for proper language. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (8. Procurement, Suspension & Debarment.) Section 200.308 General Procurement Standards reads as follows: (a) Documented procurement procedures. The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. (b) Oversight of contractors. Recipients and subrecipients must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. See also § 200.501(h). (c) Conflicts of interest. (1) The recipient or subrecipient must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. No employee, officer, agent, or board member with a real or apparent conflict of interest may participate in the selection, award, or administration of a contract supported by the Federal award. A conflict of interest includes when the employee, officer, agent, or board member, any member of their immediate family, their partner, or an organization that employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from an entity considered for a contract. An employee, officer, agent, and board member of the recipient or subrecipient may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors. However, the recipient or subrecipient may set standards for situations where the financial interest is not substantial or a gift is an unsolicited item of nominal value. The recipient's or subrecipient's standards of conduct must also provide for disciplinary actions to be applied for violations by its employees, officers, agents, or board members. (2) If the recipient or subrecipient has a parent, affiliate, or subsidiary organization that is not a State, local government, or Indian Tribe, the recipient or subrecipient must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest mean that because of relationships with a parent company, affiliate, or subsidiary organization, the recipient or subrecipient is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. (d) Avoidance of unnecessary or duplicative items. The recipient's or subrecipient's procedures must avoid the acquisition of unnecessary or duplicative items. Consideration should be given to consolidating or breaking out procurements to obtain a more economical purchase. When appropriate, an analysis should be made between leasing and purchasing property or equipment to determine the most economical approach. (e) Procurement arrangements using strategic sourcing. When appropriate for the procurement or use of common or shared goods and services, recipients and subrecipients are encouraged to enter into State and local intergovernmental agreements or inter-entity agreements for procurement transactions. These or similar procurement arrangements using strategic sourcing may foster greater economy and efficiency. Documented procurement actions of this type (using strategic sourcing, shared services, and other similar procurement arrangements) will meet the competition requirements of this part. (f) Use of excess and surplus Federal property. The recipient or subrecipient is encouraged to use excess and surplus Federal property instead of purchasing new equipment and property when it is feasible and reduces project costs. (g) Use of value engineering clauses. When practical, the recipient or subrecipient is encouraged to use value engineering clauses in contracts for construction projects of sufficient size to offer reasonable opportunities for cost reductions. Value engineering means analyzing each contract item or task to ensure its essential function is provided at the overall lowest cost. (h) Responsible contractors. The recipient or subrecipient must award contracts only to responsible contractors that possess the ability to perform successfully under the terms and conditions of a proposed contract. The recipient or subrecipient must consider contractor integrity, public policy compliance, proper classification of employees (see the Fair Labor Standards Act, 29 U.S.C. 201, chapter 8), past performance record, and financial and technical resources when conducting a procurement transaction. See also § 200.214. (i) Procurement records. The recipient or subrecipient 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. (j) Time-and-materials type contracts. (1) The recipient or subrecipient may use a time-and-materials type contract only after a determination that no other contract is suitable and if the contract includes a ceiling price that the contractor exceeds at its own risk. Time-and-materials type contract means a contract whose cost to a recipient or subrecipient is the sum of: (i) The actual cost of materials; and (ii) Direct labor hours charged at fixed hourly rates that reflect wages, general and administrative expenses, and profit. (2) Because this formula generates an open-ended contract price, a time-and-materials contract provides no positive profit incentive to the contractor for cost control or labor efficiency. Therefore, each contract must set a ceiling price that the contractor exceeds at its own risk. Further, the recipient or subrecipient awarding such a contract must assert a high degree of oversight to obtain reasonable assurance that the contractor is using efficient methods and effective cost controls.
CFDA No. 14.228 – Community Development Block Grant Year Ended – May 31, 2024 Passed Through the NEW York State Housing Trust Fund Federal Agency – U.S. Department of Housing and Urban Development Criteria – the Village’s procurement policy must incorporate federal award activity within the process and procedures followed by the Village in accordance with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), sections 200.112, 200.317-200.326. Under the Uniform Guidance, the procurement requirements were required to be implemented by January 1, 2018 for federal award recipients. Condition – The Village’s code of ethics, conflict of interest and procurement policies have not been updated to comply with the requirements in the Uniform Guidance. Cause – The control environment related to the requirements of the Uniform Guidance has not be reviewed and incorporated into the Village’s control activities through the updating and documentation of the Village’s policies noted above. Effect – The Village was not in compliance with the requirements of the Uniform Guidance, Section 200.112, Conflict of Interest and Sections 200.317-200.326, Procurement Standards. Questioned Costs – There were no questioned costs noted related to this finding. Context – This finding was identified during inquiries of management in regards to the control environment over the requirements of the Uniform Guidance and through the review of the related policies noted above. Recommendation – We recommend the Village review their policies and establish/update such policies to ensure compliance with the Uniform Guidance. Village’s Response – The Village Mayor will continue working with the consultants to update the required policies and procedures to ensure compliance during this next year.
CFDA No. 14.228 – Community Development Block Grant Year Ended – May 31, 2024 Passed Through the NEW York State Housing Trust Fund Federal Agency – U.S. Department of Housing and Urban Development Criteria – the Village’s procurement policy must incorporate federal award activity within the process and procedures followed by the Village in accordance with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), sections 200.112, 200.317-200.326. Under the Uniform Guidance, the procurement requirements were required to be implemented by January 1, 2018 for federal award recipients. Condition – The Village’s code of ethics, conflict of interest and procurement policies have not been updated to comply with the requirements in the Uniform Guidance. Cause – The control environment related to the requirements of the Uniform Guidance has not be reviewed and incorporated into the Village’s control activities through the updating and documentation of the Village’s policies noted above. Effect – The Village was not in compliance with the requirements of the Uniform Guidance, Section 200.112, Conflict of Interest and Sections 200.317-200.326, Procurement Standards. Questioned Costs – There were no questioned costs noted related to this finding. Context – This finding was identified during inquiries of management in regards to the control environment over the requirements of the Uniform Guidance and through the review of the related policies noted above. Recommendation – We recommend the Village review their policies and establish/update such policies to ensure compliance with the Uniform Guidance. Village’s Response – The Village Mayor will continue working with the consultants to update the required policies and procedures to ensure compliance during this next year.
U.S. Department of Housing and Urban Development Federal Financial Assistance Listing #14.134 Mortgage Insurance Rental Housing Project Number: 091-11022 HUD Regulatory Agreement Dated July 1, 2016 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CRF 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327 which also requires documentation to be retained to detail the history of procurements. In addition, as outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contactor registry. Condition: There was one vendor with expenditures in excess of $25,000 and the Project did not verify the vendor against the central contractor registry prior to entering into the transaction or on a periodic basis to ensure that the vendor was not suspended or debarred. Prior to adoption of a procurement policy, management entered into a transaction over the micropurchase threshold with a vendor and documentation was unable to be provided to support procurement compliance for the vendor. Cause: The Project adopted a written procurement policy which conforms to Uniform Guidance during May 2023 and therefore, the Project did not have a policy in place to follow from January through May. Management overlooked the requirement to verify the vendor against the central contractor registry for a vendor. Effect: Inadequate controls over this area of compliance result in a reasonable possibility that the Project would not have the required documentation in place and would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: $23,335 Context/Sampling: A nonstatistical sample of 4 of 8 transactions applicable to procurement requirements were selected for testing, which accounted for $95,590 of $199,971 of transactions. In addition, there was one vendor in which suspension and debarment requirements were applicable and the vendor was tested. Repeat Finding from Prior Year: Yes Recommendation: Management implemented formal procedures over procurement during May 2023 and we recommend management continue following those formal procedures. In addition, we recommend management implement formal procedures over suspension and debarment and retain sufficient documentation to support the process was followed. Views of Responsible Officials: Management agrees with the finding and recommendation.
Assistance Listing Number 66.468 Drinking Water State Revolving Fund United States Environmental Protection Agency North Dakota Public Finance Authority Procurement Suspension & Debarment 2 CFR Part 200.318 Criteria 2 CFR Part 200.318 states that a non-Federal entity must have and use documented procedures, consistent with state, local, and tribal laws and regulations and the standards of 2 CFR part 200.317 through 200.327. Condition District does not have a written procurement policy in place. Cause The District has not approved a written procurement policy. Effect Non-compliance with Procurement Suspension & Debarment compliance requirements. Questioned Costs Not Applicable Repeat Finding See 2022-005. Recommendation We recommend for the board of the District to create and implement a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327. Views of Responsible Officials and Planned Corrective Actions The District will create and approve a procurement policy that adheres to state and local regulations as well as 2 CFR Part 200.317 through 200.327.
Finding 2023-002: Procurement and Suspension and Debarment Identification of federal program: Program Titles: Agriculture Research Basic and Applied Research & Community Economic Adjustment Assistance for Compatible Use and Joint Land Use Studies Assistance Listing Numbers: 10.001 & 12.610 Award Identification: CA 59-8082-0-001 & W9124J2120002 Federal Agencies: U.S. Department of Agriculture, Agriculture Research Service & U.S. Department of Defense, Office of Local Defense Community Cooperation Criteria or Specific Requirement: 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. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: While the Fund adopted an updated procurement policy during 2023, testing of the Fund’s controls on compliance over procurement and suspension and debarment identified transactions under the old policy. The Fund did not have a procurement policy in place for the full year that is in compliance with prescribed standards in the Uniform Guidance; therefore, prior to the adoption of the updated procurement policy, suspension and debarment verifications were not performed prior to entering a covered transaction. Cause: While the Fund adopted an updated procurement policy, including policies over suspension and debarment that fully conforms to Uniform Guidance, the policy was adopted during 2023. Effect: The Fund was not in compliance with the procurement policy requirements of Uniform Guidance, specifically around suspension and debarment for the entirety of 2023. Questioned Costs: None Context: The Fund adopted an updated procurement policy in 2023, which fully complies with Uniform Guidance requirements addressed in Chapter 2 Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. As the policy was not in place for the full year, we are unable to adequately test compliance prior to the adoption of the new policy. Repeat finding: Yes, Finding 2022-002 Recommendation: We acknowledge the Fund adopted and documented procurement procedures, which conform to the procurement standards identified in 2 CFR section §§ 200.317 through 200.327, and also addressed suspension and debarment during 2023. We recommend management continue training to ensure all applicable personnel are familiar with the revised policy. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2023-002: Procurement and Suspension and Debarment Identification of federal program: Program Titles: Agriculture Research Basic and Applied Research & Community Economic Adjustment Assistance for Compatible Use and Joint Land Use Studies Assistance Listing Numbers: 10.001 & 12.610 Award Identification: CA 59-8082-0-001 & W9124J2120002 Federal Agencies: U.S. Department of Agriculture, Agriculture Research Service & U.S. Department of Defense, Office of Local Defense Community Cooperation Criteria or Specific Requirement: 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. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: While the Fund adopted an updated procurement policy during 2023, testing of the Fund’s controls on compliance over procurement and suspension and debarment identified transactions under the old policy. The Fund did not have a procurement policy in place for the full year that is in compliance with prescribed standards in the Uniform Guidance; therefore, prior to the adoption of the updated procurement policy, suspension and debarment verifications were not performed prior to entering a covered transaction. Cause: While the Fund adopted an updated procurement policy, including policies over suspension and debarment that fully conforms to Uniform Guidance, the policy was adopted during 2023. Effect: The Fund was not in compliance with the procurement policy requirements of Uniform Guidance, specifically around suspension and debarment for the entirety of 2023. Questioned Costs: None Context: The Fund adopted an updated procurement policy in 2023, which fully complies with Uniform Guidance requirements addressed in Chapter 2 Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. As the policy was not in place for the full year, we are unable to adequately test compliance prior to the adoption of the new policy. Repeat finding: Yes, Finding 2022-002 Recommendation: We acknowledge the Fund adopted and documented procurement procedures, which conform to the procurement standards identified in 2 CFR section §§ 200.317 through 200.327, and also addressed suspension and debarment during 2023. We recommend management continue training to ensure all applicable personnel are familiar with the revised policy. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Criteria or specific requirement: Part 2 of the Code of Federal Regulations (CFR), Sections 200.317 through 200.326 describe specific federal requirements related to procurement actions and documented procurement policies for federal award recipients. These standards require various elements, such as addressing conflicts of interests, avoiding acquisition of unnecessary or duplicative items, maintaining records sufficient to detail the history of the procurement, and conducting procurement in a manner that provides full and open competition, and adherence to the required methods of procurement for the acquisition of property and services. These Uniform Guidance standards have been updated several times in the past few years. Part 2 CFR, Section 180.300 describes federal requirements related to suspension and debarment for federal award recipients. The standards require that a federal award recipient verify that an entity with which it plans to enter into a covered transaction is not suspended and debarred. Procedures for satisfying such requirements should be documented, and evidence of such procedures should be maintained. Condition: The Organization’s procurement policy does not address all federally required elements of procurement policies under 2 CFR 200.317 through 200.326. Specifically, some of the items absent from the Organization’s procurement policy include: certain federally defined methods of procurement, open-competition clauses, and clauses related to acquisition of unnecessary and duplicative items. The Organization also does not have a written policy that specifies its suspension and debarment procedures. As a result, the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. During our audit procedures, we noted that the vendor was not suspended and debarred. Questioned costs: None Context: Based on our review of the Organization's procurement policy, we noted that several federally required elements were absent from the policy. We also noted that the Organization did not have a documented suspension and debarment policy, and as a result the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. Cause: The Organization’s procurement policy has not been revised to address all federally required elements specified in the Uniform Guidance. The Organization also does not have a documented suspension and debarment policy. Effect: The Organization is not in compliance with federal requirements related to a documented procurement policy, and documented suspension and debarment procedures. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization update its procurement policy to include all federally required elements of such policies for federal award recipients under the Uniform Guidance. We also recommend that the Organization document and maintain evidence of its suspension and debarment procedures to be in compliance with requirements specified in the Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Part 2 of the Code of Federal Regulations (CFR), Sections 200.317 through 200.326 describe specific federal requirements related to procurement actions and documented procurement policies for federal award recipients. These standards require various elements, such as addressing conflicts of interests, avoiding acquisition of unnecessary or duplicative items, maintaining records sufficient to detail the history of the procurement, and conducting procurement in a manner that provides full and open competition, and adherence to the required methods of procurement for the acquisition of property and services. These Uniform Guidance standards have been updated several times in the past few years. Part 2 CFR, Section 180.300 describes federal requirements related to suspension and debarment for federal award recipients. The standards require that a federal award recipient verify that an entity with which it plans to enter into a covered transaction is not suspended and debarred. Procedures for satisfying such requirements should be documented, and evidence of such procedures should be maintained. Condition: The Organization’s procurement policy does not address all federally required elements of procurement policies under 2 CFR 200.317 through 200.326. Specifically, some of the items absent from the Organization’s procurement policy include: certain federally defined methods of procurement, open-competition clauses, and clauses related to acquisition of unnecessary and duplicative items. The Organization also does not have a written policy that specifies its suspension and debarment procedures. As a result, the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. During our audit procedures, we noted that the vendor was not suspended and debarred. Questioned costs: None Context: Based on our review of the Organization's procurement policy, we noted that several federally required elements were absent from the policy. We also noted that the Organization did not have a documented suspension and debarment policy, and as a result the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. Cause: The Organization’s procurement policy has not been revised to address all federally required elements specified in the Uniform Guidance. The Organization also does not have a documented suspension and debarment policy. Effect: The Organization is not in compliance with federal requirements related to a documented procurement policy, and documented suspension and debarment procedures. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization update its procurement policy to include all federally required elements of such policies for federal award recipients under the Uniform Guidance. We also recommend that the Organization document and maintain evidence of its suspension and debarment procedures to be in compliance with requirements specified in the Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Part 2 of the Code of Federal Regulations (CFR), Sections 200.317 through 200.326 describe specific federal requirements related to procurement actions and documented procurement policies for federal award recipients. These standards require various elements, such as addressing conflicts of interests, avoiding acquisition of unnecessary or duplicative items, maintaining records sufficient to detail the history of the procurement, and conducting procurement in a manner that provides full and open competition, and adherence to the required methods of procurement for the acquisition of property and services. These Uniform Guidance standards have been updated several times in the past few years. Part 2 CFR, Section 180.300 describes federal requirements related to suspension and debarment for federal award recipients. The standards require that a federal award recipient verify that an entity with which it plans to enter into a covered transaction is not suspended and debarred. Procedures for satisfying such requirements should be documented, and evidence of such procedures should be maintained. Condition: The Organization’s procurement policy does not address all federally required elements of procurement policies under 2 CFR 200.317 through 200.326. Specifically, some of the items absent from the Organization’s procurement policy include: certain federally defined methods of procurement, open-competition clauses, and clauses related to acquisition of unnecessary and duplicative items. The Organization also does not have a written policy that specifies its suspension and debarment procedures. As a result, the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. During our audit procedures, we noted that the vendor was not suspended and debarred. Questioned costs: None Context: Based on our review of the Organization's procurement policy, we noted that several federally required elements were absent from the policy. We also noted that the Organization did not have a documented suspension and debarment policy, and as a result the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. Cause: The Organization’s procurement policy has not been revised to address all federally required elements specified in the Uniform Guidance. The Organization also does not have a documented suspension and debarment policy. Effect: The Organization is not in compliance with federal requirements related to a documented procurement policy, and documented suspension and debarment procedures. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization update its procurement policy to include all federally required elements of such policies for federal award recipients under the Uniform Guidance. We also recommend that the Organization document and maintain evidence of its suspension and debarment procedures to be in compliance with requirements specified in the Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Part 2 of the Code of Federal Regulations (CFR), Sections 200.317 through 200.326 describe specific federal requirements related to procurement actions and documented procurement policies for federal award recipients. These standards require various elements, such as addressing conflicts of interests, avoiding acquisition of unnecessary or duplicative items, maintaining records sufficient to detail the history of the procurement, and conducting procurement in a manner that provides full and open competition, and adherence to the required methods of procurement for the acquisition of property and services. These Uniform Guidance standards have been updated several times in the past few years. Part 2 CFR, Section 180.300 describes federal requirements related to suspension and debarment for federal award recipients. The standards require that a federal award recipient verify that an entity with which it plans to enter into a covered transaction is not suspended and debarred. Procedures for satisfying such requirements should be documented, and evidence of such procedures should be maintained. Condition: The Organization’s procurement policy does not address all federally required elements of procurement policies under 2 CFR 200.317 through 200.326. Specifically, some of the items absent from the Organization’s procurement policy include: certain federally defined methods of procurement, open-competition clauses, and clauses related to acquisition of unnecessary and duplicative items. The Organization also does not have a written policy that specifies its suspension and debarment procedures. As a result, the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. During our audit procedures, we noted that the vendor was not suspended and debarred. Questioned costs: None Context: Based on our review of the Organization's procurement policy, we noted that several federally required elements were absent from the policy. We also noted that the Organization did not have a documented suspension and debarment policy, and as a result the Organization was not able to provide evidence that it verified a vendor with which it entered into a cover transaction was not suspended and debarred before the date it entered into the transaction with such vendor. Cause: The Organization’s procurement policy has not been revised to address all federally required elements specified in the Uniform Guidance. The Organization also does not have a documented suspension and debarment policy. Effect: The Organization is not in compliance with federal requirements related to a documented procurement policy, and documented suspension and debarment procedures. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization update its procurement policy to include all federally required elements of such policies for federal award recipients under the Uniform Guidance. We also recommend that the Organization document and maintain evidence of its suspension and debarment procedures to be in compliance with requirements specified in the Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.