Finding: Finding Type: Material Weakness Title and Federal Assistance Listing Number of Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: In accordance with 2 CFR 200.320, non-federal entities must conduct all procurement transactions in a manner providing full and open competition. For purchases exceeding the micro-purchase threshold of $10,000, the entity must obtain price or rate quotations from an adequate number of qualified sources, unless the purchase qualifies as a sole-source procurement under 2 CFR 200.320(c). Additionally, 2 CFR 200.303 requires the non-federal entity to establish and maintain effective internal control over compliance with federal statutes, regulations, and the terms and conditions of the federal award. Furthermore, 2 CFR 200.318(b) and 200.324 require that written contracts be executed with contractors, including all required Federal provisions to safeguard Federal funds. Condition: We examined 60 transactions during our testing of procurement transactions under the Coronavirus State and Local Fiscal Recovery Funds. We noted that a competitive bidding process was not used in 42 of 60 transactions tested. In all 42 instances, Historic South did not provide evidence that multiple bids or quotes were solicited. The documentation and explanation provided by Historic South was not deemed to be adequate justification to qualify for the use of sole-source procurement under 2 CFR 200.320(c). Additionally, all 60 procurement transactions tested did not have a fully executed, signed contract with the respective contractors. The award/contracting process and methods used to render and pay services did not meet the expected level of formal contractual agreements in place. Cause: In early 2024, Historic South made revisions to the procurement process in order to maximize efficiency and improve overall project outcomes. These revisions were made based on the challenges of securing bids on all potential projects, the need to expend the awarded dollars in a timely fashion and a verbal agreed-upon understanding with the Ohio Department of Health. The requirement to obtain multiple bids was replaced with a strategic invitation approach based on a preferred vendor pool. The result was that Historic South did not have a procedure in place to ensure that procurement transactions were conducted in compliance with Uniform Guidance. Specifically, the procurement policy lacked provisions to enforce competitive procurement practices for purchases above the micro-purchase threshold. Additionally, the process Historic South used to make awards to contractors did not meet the expected standards required for formal contract execution prior to project initiation or payment. - 29 - Historic South Initiative Schedule of Findings and Questioned Costs - continued Year Ended December 31, 2024 Section III – Federal Program Audit Findings and Questioned Costs - continued Effect: Failure to obtain competitive bids or quotes increases the risk of paying higher prices for goods/services, or unfair contracting practices. Additionally, the lack of competitive procurement represents noncompliance with Uniform Guidance, which may lead to questioned costs and potential disallowance by the granting agency. Furthermore, the lack of formally signed contracts increases the risk of misuse of federal funds and an inability to enforce contractual obligations or resolve disputes. While our testing did not identify any instances of misspent or improperly used federal funds, the control deficiencies represent a material weakness in internal control over compliance. Questioned Costs: $1,555,114 These costs are considered questioned due to lack of compliance with Uniform Guidance. The amount represents the total bid/contract amount of the 42 transactions tested, that did not meet the competitive bidding requirements. Recommendation: We recommend that Historic South implement and enforce formal procurement procedures that comply with the requirements of 2 CFR 200.317-200.327. These procedures should include obtaining competitive bids and/or maintaining documentation for any alternative bidding process used and approval requirements. Additionally, Historic South should require that fully executed, signed contracts be obtained prior to the start of work or payment to contractors. Staff responsible for procurement should be trained on federal procurement standards to ensure compliance. Views of Responsible Official and Planned Corrective Action: Prospectively, Historic South will review best practices related to the contract awarding process and formal contracting arrangements for construction work. In addition, Historic South will implement policies of: 1. Requiring the solicitation of multiple bids for all construction work in excess of $10,000 2. Establishing criteria for awarding all construction work 3. Implementing formal contracting processes for all construction work
Finding 2024-001 – Noncompliance with Procurement Standards – Professional Services Federal Program: Coronavirus State and Local Fiscal Recovery Funds (Covid-19), ALN #21.027 Criteria: Uniform Guidance requires non-federal entities to maintain documented procurement procedures that ensure full and open competition (2 CFR §200.318). For procurements within the small purchase threshold, nonfederal entities are required to obtain price or rate quotations from an adequate number of qualified sources (2 CFR §200.320). Professional service contracts are subject to these requirements. Condition: The auditee did not follow established procurement policies and the procurement standards set forth in 2 CFR §200.317–§200.327 when engaging legal counsel. Specifically, the auditee procured legal services with total costs between $10,000 and $250,000 without obtaining and documenting required price or rate quotations or performing a documented evaluation of qualified firms. Cause: The auditee did not document a noncompetitive procurement justification or otherwise comply with the small purchase procurement requirements because it was not aware that professional legal services were subject to standards under Uniform Guidance. Additionally, at the time the legal services were engaged, management did not anticipate that the related expenditures would be subject to a Single Audit. Effect: Failure to follow required procurement procedures increases the risk of noncompliance with federal regulations and may result in questioned costs if the expenditures are determined to be unallowable. Context: The audit finding represents an isolated instance. The amount of the audit finding was $22,672 out of the total of $4,605,256 for the program and was discovered using a valid judgmentally selected sample size. Recommendation: We recommend the auditee strengthen internal controls over procurement by ensuring all professional service contracts within the $10,000 to $250,000 threshold comply with federal procurement standards, including obtaining and documenting price or rate quotations from qualified sources and documenting justification for any noncompetitive procurements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and plans to reinforce procurement requirements, and implement review procedures to ensure compliance with procurement thresholds and documentation requirements prior to contract execution.
(#2024-002) Policy Updates for Uniform Guidance – CFDA No. 21.027 – Coronavirus State and Local Fiscal Recovery Funds Year Ended – December 31, 2024 Direct Program Federal Agency – U.S. Department of Agriculture Criteria – the Town’s procurement policy must incorporate federal award activity within the process and procedures followed by the Town 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 Town’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 Town’s control activities through the updating and documentation of the Town’s policies noted above. Effect – The Town 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 Town review their policies and establish/update such policies to ensure compliance with the Uniform Guidance. Town’s Response – The Town will make every effort in the future to record accruals and present the financial statements in accordance with generally accepted accounting principles.
U.S. Department of Treasury passed through State of Utah Department of Workforce Services and through Colorado Department of Human Services 2024-002: Procurement and Suspension and Debarment Program: Coronavirus State and Local Fiscal Recovery Funds (21.027) Criteria: Recipients of federal awards must follow the procurement standards set out at 2 CFR section 200.317 through 200.326. They must use their own documented procurement procedures, which reflect applicable State laws and regulations, provided that the procedures conform to applicable Federal law and the procurement requirements identified in 2 CFR part 200. Recipients “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 section 200.318(i). Context and condition: We selected five contracts to test for compliance with procurement standards. Records for three contracts lacked documentation sufficient to detail procurement history. Cause: The Academy did not follow its procurement policy for publicly soliciting bids. Effect: A potential failure to conduct procurement transactions in a manner providing full and open competition exists. Questioned costs: No costs were questioned. Recommednation: We recommend the Academy ensure it 1) maintains documentation of the history of procurement and 2) monitors compliance with documentation requirements. Views of responsible officials: The Academy will review its procurement policies and internal controls and ensure timely action is taken when noncompliance is identified.
ALN 14.251 and ALN 21.027 Finding #2024‐003 Subrecipient Monitoring Repeat Finding: No Condition: The Organization did not perform adequate monitoring of its subrecipient to ensure compliance with federal procurement and suspension/debarment requirements. Specifically: · The subrecipient did not have procurement policies that conform to the Uniform Guidance requirements at 2 CFR 200.317–200.327. · The subrecipient did not perform suspension or debarment verifications for vendors, as required by 2 CFR 200.214. · The Organization, as pass‐through entity, did not identify or address these deficiencies through its monitoring procedures. Criteria: In accordance with 2 CFR 200.332(d), pass‐through entities are required to monitor the activities of subrecipients as necessary to ensure that subawards are used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, 2 CFR 200.317–200.327 establish procurement standards applicable to non‐federal entities, including the requirement to have written procurement procedures that conform to applicable federal law and standards. Under 2 CFR 200.214, non‐federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Cause: The Organization’s monitoring procedures did not include a review of subrecipient procurement policies and practices, nor did they require confirmation that the subrecipient was performing suspension/debarment checks. Effect: There is an increased risk that federal funds could be expended on unallowable costs, including purchases from suspended or debarred vendors. Lack of proper procurement policies also creates a risk that procurements may not be conducted in a manner providing full and open competition, as required by federal regulations. Questioned Costs: None at this time. Perspective Information: The condition noted applied to the subrecipient responsible for administering $1,525,133 of the Organization’s federal expenditures under ALN 14.251 and $900,000 of the Organization’s pass‐through funds expenditures under ALN 21.027. This represents 100% of the Organization’s subrecipient expenditures for the program. Accordingly, the lack of subrecipient procurement and debarment compliance is considered systemic to the subrecipient relationship and not an isolated instance. Recommendation: We recommend that the Organization strengthen its subrecipient monitoring procedures to include verification that subrecipients have procurement policies in compliance with Uniform Guidance and are performing suspension and debarment checks prior to entering into vendor agreements. The Organization should provide training and technical assistance to subrecipients to help them implement compliant procurement and debarment procedures. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization has partnered with a firm to administer the development of the project and was unaware of its responsibilities to monitor the subrecipient relating to procurement and debarment. The Organization is in process of implementing procedures to ensure the subrecipient complies with the requirements of the Uniform Guidance.
ALN 14.251 and ALN 21.027 Finding #2024‐006 Financial Policies and Procedures Repeat Finding: No Condition: The Organization did not have formalized, written financial policies and procedures that address key Uniform Guidance requirements. Criteria: Under 2 CFR 200.302(b), non‐federal entities must establish and maintain effective financial management systems that provide accurate, current, and complete disclosure of the financial results of each federal award. Uniform Guidance further requires that entities implement written policies and procedures governing: · Allowable costs (2 CFR 200.302(b)(7) and 200.403–200.405), · Procurement (2 CFR 200.317–200.327), · Cash management (2 CFR 200.305), · Travel costs (2 CFR 200.475), and · Conflict of interest (2 CFR 200.318(c)(1)). Written policies serve as the framework for consistent compliance with federal requirements. Cause: The Organization had not developed or adopted written financial policies, relying instead on informal practices and staff knowledge to manage federal awards. Effect: The absence of formalized financial policies increases the risk of noncompliance with Uniform Guidance, inconsistent application of requirements, and potential misuse of federal funds. The lack of a documented framework also limits accountability and makes it difficult to train new staff or demonstrate compliance to oversight agencies. Questioned Costs: None noted. Perspective Information: This condition applied to the Organization’s overall financial management system and impacted all federal programs administered during the year ended December 31, 2024. As such, the lack of formalized financial policies represents a systemic issue and a material weakness in internal control over compliance. Recommendation: We recommend that the Organization adopt formal, written financial policies and procedures that address all Uniform Guidance requirements applicable to federal awards. These policies should be approved by management and the governing body, disseminated to staff, and reviewed periodically to ensure continued compliance. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance.
Finding #2024‐008 Procurement, Suspension/Debarment Repeat Finding: No Condition: During testing of procurement transactions, it was noted that the Organization did not perform required procurement procedures or suspension/debarment verifications prior to executing contracts funded by federal awards. Specifically, the Organization did not document competitive procurement processes or maintain supporting documentation to demonstrate compliance with Uniform Guidance procurement standards. No evidence was provided that vendors were checked against SAM.gov or otherwise verified to ensure they were not suspended or debarred at the time of award. Criteria: Under 2 CFR 200.317 through 200.327, non‐federal entities must follow procurement standards that promote full and open competition, include written procurement procedures, and maintain records sufficient to detail the history of procurements. Additionally, per 2 CFR 200.214, non‐federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred. Entities must verify vendor eligibility by checking the System for Award Management (SAM.gov) or by obtaining a vendor certification prior to award. Cause: The Organization lacked formal procurement policies and internal controls to ensure Uniform Guidance procurement and debarment procedures were followed. Responsibility for compliance was not clearly assigned, and no review process existed to confirm that required verifications were completed. Effect: Failure to follow federal procurement and debarment requirements represents a material weakness in internal control over compliance and increases the risk that: Contracts could be awarded to suspended or debarred vendors; purchases may not reflect fair and open competition; and Federal funds could be expended on unallowable costs. Questioned Costs: None at this time. Perspective Information: This condition applied to all federal procurement transactions tested during the year ended June 30, 2025, totaling approximately $51,520 in expenditures. Recommendation: We recommend that the Organization: · Develop and implement written procurement policies that comply with 2 CFR 200.317–200.327. · Require staff to perform and document SAM.gov checks (or equivalent verification) prior to entering into any federally funded contracts. · Maintain procurement documentation that includes bids, quotes, selection rationale, and evidence of price reasonableness. · Provide training to staff on Uniform Guidance procurement and debarment requirements. · Establish a review and approval process to verify compliance before purchases are finalized. Reporting Views of Responsible Officials: The Organization agrees with the finding. The Organization will establish formalized financial policies that comply with procurement and debarment requirements of the Uniform Guidance and ensure compliance with such policies when procuring vendors.
Criteria: Uniform Guidance 2 CFR Part 200.318 require that AEA have documented procurement procedures for procurement transactions under a Federal award or subaward. Condition: AEA follows the Weather Assistance Program Policies and Procedures Manual which has a procurement and suspension and debarment policy; however, AEA did not formally adopt a written policy that complies with the Office of Management and Budget’s (the “OMB”) requirements for procurement suspension and debarment. Cause: AEA did not formally adopt a written policy that complies with OMB requirements for procurement suspension and debarment. Effect: AEA 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 AEA formally adopt a written procurement and suspension and debarment policy in accordance with the requirements. View of Responsible Officials: See management’s corrective action plan.
FINDING 2024-001 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Noncompliance 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 awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)...." 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 documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (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. . . . “ 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 the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Cause: The City had not developed a system of internal controls that would have ensured compliance with Procurement and Suspension and Debarment compliance requirements for covered transactions. 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. The failure to comply with the grant agreement and the compliance requirement could have resulted in the loss of federal funds to the City. Questioned costs: There are no questioned costs. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Identification as a repeat finding, if applicable: Yes, finding 2023-003 in the prior year report. Recommendation: We recommend that the City establish and implement control procedures to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. This should include ensuring proper procurement methods are followed, suspension and debarment checks are performed and documented prior to entering into the transaction. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: U.S. Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Numbers and Years (or Other Identifying Numbers): Contract #65873, SLT-3157 Pass-Through Entity: Indiana Department of Natural Resources Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2023-004. Condition and Context Procurement The County did adopt an applicable federal purchasing policy. The Lake County Indiana Purchasing Manual for Supplies, Services, and Public Works states on page 19 that "Federal funds less than $25,000 will obtain 3 quotes by telephone or fax and obtain board approval. . . ." The Lake County Indiana Purchasing Manual for Supplies, Services, and Public Works also states on page 19 that "Federal funds more than $25,000 but less than $50,000 will invite 3 quotes at an open public meeting." The federal procurement requirement, per the Code of Federal Regulations section 200.320, states that for small purchases, price or rate quotations must be obtained from an adequate number of qualified sources. In 2024, the County had two vendors. One was paid $27,963, and one was paid $12,970 for a total of $40,933 from the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under Contract #65873 from the Indiana Department of Natural Resources. However, the County did not obtain price or rate quotes for the applicable vendors under the small purchase threshold as required per its purchasing policy or the federal requirements. Suspension and Debarment Prior to entering into subawards and covered transactions with the SLFRF 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 and all subawards. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person or entity, or adding a clause or condition to the covered transaction with that person or entity. The County did not have policies or procedures in place related to the suspension and debarment requirements for the SLFRF funds. Three covered transactions totaling $7,530,563 paid from the SLFRF funds were identified. Documentation to show that suspension and debarment was verified prior to entering into contracts with these three vendors could not be provided by the County. The amounts for which suspension and debarment were not verified for Contract #65873 from the Indiana Department of Natural Resources and the SLT-3157 directly from the U.S. Department of the Treasury were $27,963 and $7,502,600, respectively. The lack of internal controls and noncompliance were isolated to the transactions identified above. 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(i) states: "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. . . ." 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 The County's purchasing policy does not provide procedures on how the County will ensure the appropriate number of quotes will be obtained for small purchases or how the County will ensure compliance with the suspension and debarment requirements. Effect Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the repayment or loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation Management of the County should develop procedures to ensure the appropriate procurement methods are used for items or services procured that are within the small purchase threshold and to ensure vendors are not suspended or debarred when expending federal funds. Appropriate documentation should be maintained to ensure compliance with procurement and suspension and debarment. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
MATERIAL WEAKNESSES 2024-001 - Procurement Federal Program Information: US Department of Treasury: ALN - 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317-327, 2 CFR section 200.314, 2 CFR 200 Appendix II. Condition: The procurement history file did not include the contract or documentation containing the required provisions. Cause: The County does not have the necessary understanding of the requirement to be able to understand the necessary internal controls over compliance at the time the contract was signed. Effect: The County did not require a contract which resulted in required procurement provisions such as the termination clause, Davis Bacon requirement. This increases the likelihood of restricted or loss of federal funds. Identification of Questioned Costs: None identified. Context: There was one new procurement in FY 24 that was tested. The procurement was missing the contract and other required provision documentation. Repeat Finding: This is a repeat finding of 2022-001 and 2023-001 Recommendation: It is recommended that the County implement internal control processes and procedures to ensure that federal reimbursements requests are submitted on a timely basis. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the County of Aroostook, Maine.
2024-003 Procurement, Suspension and Debarment Federal Agency(ies): United States Department of Defense Federal Program(s): Research and Development Cluster Assistance Listing Number(s): 12.300, 12.330 Pass-through Entity (if applicable): Direct awards and pass-through awards from RTI International and Greensight, Inc. Award Identification Number and Year: Various Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR 200.317 through 2 CFR 200.327, non-Federal entities are required to maintain documentation sufficient to detail the history of procurement transactions. Such documentation should include, as applicable, the rationale for the method of procurement, contractor selection, basis for contract price, and the basis for any sole-source procurement. Additionally, pursuant to 2 CFR 180 and 2 CFR 200.214, non-Federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred and should maintain documentation demonstrating that applicable vendors were screened prior to contracting or payment. Condition: As part of our testing of vendor expenditures charged to Federal awards within the Research and Development Cluster, we selected a statistical sample of procurement transactions and noted deficiencies in RoboNation's procurement and suspension and debarment documentation. Specifically, we noted instances in which RoboNation did not consistently document the rationale supporting its selection of vendors charged to Federal awards. In addition, for procurements utilizing a sole-source or noncompetitive procurement methodology, RoboNation did not consistently document which of the allowable exceptions under 2 CFR 200.320 justified the use of noncompetitive procurement. With respect to suspension and debarment requirements, we noted that RoboNation did not consistently maintain evidence that vendors were screened against the System for Award Management (SAM.gov) database prior to contracting or payment. We also identified instances in which SAM.gov screening reports were either undated or dated after execution of the vendor agreement and related payment activity. Cause: RoboNation's policies and procedures for procurement documentation and suspension and debarment compliance were not operating effectively. Specifically, controls were not sufficient to ensure that procurement files contained required support for vendor selection and sole-source procurements, nor were controls adequate to ensure that SAM.gov screenings were completed and documented prior to engaging vendors charged to Federal awards. Effect or Potential Effect: The lack of adequate procurement and suspension and debarment documentation increases the risk that procurement transactions may not comply with Uniform Guidance requirements and that vendors could be selected without sufficient support for the procurement method utilized. Additionally, the lack of timely and documented SAM.gov screenings increases the risk that Federal funds could be expended on vendors that are suspended or debarred from participation in Federally funded programs. Questioned Costs: $539,394 Context: As part of our testing of the Procurement, Suspension, and Debarment compliance requirements for the Research and Development Cluster, we selected a statistical sample of vendor transactions charged to Federal awards during the year ended December 31, 2024. Identification as a Repeat Finding, if Applicable: Yes, repeat of 2023-002 and 2023-003. Recommendation: We recommend that management strengthen controls over procurement and suspension and debarment compliance by implementing procedures requiring procurement files to contain documentation supporting vendor selection, the procurement method utilized, and, when applicable, the specific basis for sole-source procurement under Uniform Guidance. In addition, management should establish procedures to ensure that SAM.gov screenings are performed and documented prior to contract execution or payment and that evidence of such screenings is retained within the procurement file.
Finding 2024-010 – Procurement (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Condition: We selected 7 vendors for procurement testing. Of those 7, it was noted that one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College did not obtain price or rate quotes for this vendor that had provided services for several years. Effect: The College did not have appropriate documentation. Questioned Costs: $24,250 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors in the small purchase category are properly procured. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-001 – Procurement (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031 Higher Education Institutional Aid Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Condition: Of ten vendors tested, one vendor’s services was not properly bid and one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College contracted with a vendor for consulting and then retained them for on-going services. These services were not bid. The other vendor was paid more than the micro-purchase threshold during the year, but price or rate quotes were not obtained for purchases. Effect: The College did not comply with federal procurement requirements for these two exceptions. Questioned Costs: $856,476 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors are properly procured. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Criteria: 2 CFR Section 200.318 requires that 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 standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition: During testing of the Organization’s controls on compliance over procurement and suspension and debarment, we identified selected vendors the Organization did not have all the needed documentation around the procurement process and the suspension and debarment check. The Organization also must enhance its current procurement policy. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the procurement process and the suspension and debarment check. Effect: The Organization was not fully in compliance with the procurement and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Organization review its current documented procurement policy, and its current processes and controls over procurement and suspension and debarment to ensure all required elements are included and the appropriate level of documentation is retained and available.
Finding 2024-010 – Procurement (Material Weakness and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.317-327 establishes procurement standards for nonfederal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Specifically, 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. Per the City’s Fiscal Policy and Procedures Manual, the simplified acquisition method has a lower threshold of $15,000. All contracts and purchases over $15,000 must be bid. Condition: We selected eight vendors for procurement testing. Of those eight, it was noted that for five vendors the City did not document the appropriate procurement procedures took place. Cause: Minority Health - the City contracted or accumulated costs for four vendors over the simplified acquisition threshold and did not provide documentation of bid procedures. CRF - the City contracted one vendor over the simplified acquisition threshold and did not provide documentation of bid procedures. Effect: The City did not have appropriate documentation to support compliance with the procurement policy. Questioned Costs: Minority Health - $433,369; CRF - $22,813 Recommendation: We recommend the City reinforce its procurement policies through regular training and clear communication to all relevant staff members. Additionally, implementing a periodic review process to ensure compliance with this policy can help prevent future occurrences. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-010 – Procurement (Material Weakness and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.317-327 establishes procurement standards for nonfederal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Specifically, 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. Per the City’s Fiscal Policy and Procedures Manual, the simplified acquisition method has a lower threshold of $15,000. All contracts and purchases over $15,000 must be bid. Condition: We selected eight vendors for procurement testing. Of those eight, it was noted that for five vendors the City did not document the appropriate procurement procedures took place. Cause: Minority Health - the City contracted or accumulated costs for four vendors over the simplified acquisition threshold and did not provide documentation of bid procedures. CRF - the City contracted one vendor over the simplified acquisition threshold and did not provide documentation of bid procedures. Effect: The City did not have appropriate documentation to support compliance with the procurement policy. Questioned Costs: Minority Health - $433,369; CRF - $22,813 Recommendation: We recommend the City reinforce its procurement policies through regular training and clear communication to all relevant staff members. Additionally, implementing a periodic review process to ensure compliance with this policy can help prevent future occurrences. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Failure to Follow Procurement Policy Finding 2024-002 Condition: The Authority did not comply with the current procurement policy as procedures were not fully followed and forms required by the Authority’s procurement policy were not completed for the heating ventilation and cooling project, new roof, and electric vehicle charging stations. The following forms required by either 2 CFR 200 and/or the Authority’s own procurement policy were not completed for the current year capital asset purchases: Written Record of Procurement Checklist Form, Method of Procurement Decision Matrix, Advertisement and Solicitation Form, Bid Quotations, Fewer Than 3 Offers Received Evaluation if applicable, Proposal Tabulation, Certification of Compliance with Federal Clauses for the assets less than $25,000, and Responsibility Determination (sam.gov debarred verification). Criteria: The following requirements are documented in 2 CFR 200-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200.214 Suspension and Debarment Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR Part 200.318 General Procurement Standards (a) The Non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. (i) the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.320 Methods of Procurement to be Followed (b) The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. 2 CFR 200.324 Contract Cost and Price (a) The Non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals. Concurrently, the Authority’s did not comply with its own current procurement policy as it did not follow or prepare the required documentation detailed in the following sections. Procurement Requests-The Authority will maintain sufficient records to detail the history of a procurement. Such records shall include method of procurement, selection of contract type, contractor selection (or rejection), and the contract price. The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as nonresponsible and ineligible for contract award. Debarment and Suspension- The Authority will treat any prospective contractor or sub-contractor listed on a centralized State government debarment and suspension list as non-responsible and ineligible for contract awards. To see if a prospective contractor is eligible, we will look on the website www.SAM.gov and when the bid has been received. Methods of Procurement- a. Micro and Emergency Purchases (do not exceed $10,000)-(a) A written determination as to why price is deemed fair and reasonable must be on file with each purchase made under this method of procurement using Micro-Purchase Price Reasonableness Determination Form. (b) Splitting of procurements to avoid the competitive procurement requirements of federal and state statues shall not be condoned. b. Small Purchase Procurement ($10,000 to $250,000)-(a) A minimum of two price or rate quotations shall be obtained from qualified sources; (b) The procurement will be made from the lowest priced qualified bid, if products or goods are equal; (c) MDOT requires for procurements under $25,000.00. Included Procurement Appendix A, B, E, F, G, H, or I and Vehicle Specification certification if applies. (d) MDOT requires for procurements over $25,000.00 solicitations, including specifications and written selection procedures (lowest bids), Include Procurement Appendix A, F, G, H or I and Vehicle Specification certification if applies. Third Party Contracts with applicable clauses and bond documents must be included. Cause: The Authority did not follow its own procurement policy. Effect: The Authority is noncompliant with 2 CFR 200 and its own procurement policy. Directive: We direct the Authority review and update its procurement policy and implement procedures to ensure that the Authority is complying with the federal requirements, required forms are being completed, and documentation is being maintained. Management’s Response--Corrective Action Plan: Contact person is Todd Shurn, Executive Director, 275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. The Authority acknowledges the finding and is currently working to correct this.
Criteria: 2 CFR Section 200.318 requires that 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 standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition and context: During testing of the Alliance’s controls on compliance over procurement and suspension and debarment, we identified the Alliance did not have all the needed documentation around the suspension and debarment check. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the suspension and debarment check. Effect: The Alliance was not fully in compliance with the procurement and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Alliance review its current processes and controls over procurement and suspension and debarment to ensure all required documentation is retained and available. Views of Responsible Official: Management agrees with the finding. See Corrective Action Plan.
2024-001: PROCUREMENT (repeat comment) Type: Considered a material weakness in internal control over compliance/noncompliance Program: ALN 93.969 Certified Community Behavioral Health Clinics (CCBHC) Expansion Grants Criteria: Per 2 CFR section 200.318, the non-Federal entity, “…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: During testing, it was noted that the CMHSP had not followed procurement requirements for the contract entered into for project evaluation and coordination services. This is the same contract that produced a material finding in the prior year single audit. Cause/Effect: Management oversight. Questioned Cost: $150,000 – the amount paid during the fiscal year pursuant to contract in question. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that all federal requirements for procurements are followed for future contracts entered into with federal funds. Management’s Resp: Management is in agreement with this recommendation. Also, the grantor was notified of this finding and has notified the CMHSP that there is no elevated level of risk moving forward through the remainder of the grant cycle.
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Criteria: In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented 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 document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327. Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327. Questioned Costs: None Cause: The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327. Effect: The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327. Recommendation: We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Criteria: In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented 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 document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327. Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327. Questioned Costs: None Cause: The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327. Effect: The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327. Recommendation: We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
2024-001: PROCUREMENT Type: Considered a material weakness in internal control over compliance/noncompliance Program: ALN 93.696 Certified Community Behavioral Health Clinics (CCBHC) Expansion Grants Criteria: Per 2 CFR section 200.318, the non-Federal entity, “…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: During testing, it was noted that the CMHSP had not followed procurement requirements for the contract entered into for project evaluation and coordination services. Cause/Effect: Management oversight. Questioned Cost: $150,000 – the amount paid during the fiscal year pursuant to contract in question. Recommendation: We recommend that the CMHSP review/update policies and procedures to ensure that all federal requirements for procurements are followed for future contracts entered into with federal funds. Management’s Resp: Management is in agreement with this recommendation. Also, the grantor was notified of this finding and has notified the CMHSP that there is no elevated level of risk moving forward through the remainder of the grant cycle.
Finding 2024-010 – Procurement (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031 Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Condition: We selected 7 vendors for procurement testing. Of those 7, it was noted that one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College did not obtain price or rate quotes for this vendor that had provided services for several years. Effect: The College did not have appropriate documentation. Questioned Costs: $24,250 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors in the small purchase category are properly procured. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-001 – Procurement (Significant Deficiency and Noncompliance) Information on the Federal Program: U.S. Department of Education, Assistance listing # 84.031 Higher Education Institutional Aid Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Condition: Of ten vendors tested, one vendor’s services was not properly bid and one vendor was paid over the micro-purchase threshold and therefore should have obtained price or rate quotes. Cause: The College contracted with a vendor for consulting and then retained them for on-going services. These services were not bid. The other vendor was paid more than the micro-purchase threshold during the year, but price or rate quotes were not obtained for purchases. Effect: The College did not comply with federal procurement requirements for these two exceptions. Questioned Costs: $856,476 Recommendation: We recommend the College strengthen its policies and procedures over procurement to ensure vendors are properly procured. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Criteria: 2 CFR Section 200.318 requires that 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 standard identified in §§ 200.317 through 200.327 and must be adhered to. Condition: During testing of the Organization’s controls on compliance over procurement and suspension and debarment, we identified selected vendors the Organization did not have all the needed documentation around the procurement process and the suspension and debarment check. The Organization also must enhance its current procurement policy. Cause: Controls and processes were not effectively designed to ensure there was all proper documentation around the procurement process and the suspension and debarment check. Effect: The Organization was not fully in compliance with the procurement and suspension and debarment check requirements of the Uniform Guidance. Questioned Costs: None. Identification as a Repeat Finding: N/A. Recommendation: We recommend that the Organization review its current documented procurement policy, and its current processes and controls over procurement and suspension and debarment to ensure all required elements are included and the appropriate level of documentation is retained and available.
Finding 2024-010 – Procurement (Material Weakness and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.317-327 establishes procurement standards for nonfederal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Specifically, 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. Per the City’s Fiscal Policy and Procedures Manual, the simplified acquisition method has a lower threshold of $15,000. All contracts and purchases over $15,000 must be bid. Condition: We selected eight vendors for procurement testing. Of those eight, it was noted that for five vendors the City did not document the appropriate procurement procedures took place. Cause: Minority Health - the City contracted or accumulated costs for four vendors over the simplified acquisition threshold and did not provide documentation of bid procedures. CRF - the City contracted one vendor over the simplified acquisition threshold and did not provide documentation of bid procedures. Effect: The City did not have appropriate documentation to support compliance with the procurement policy. Questioned Costs: Minority Health - $433,369; CRF - $22,813 Recommendation: We recommend the City reinforce its procurement policies through regular training and clear communication to all relevant staff members. Additionally, implementing a periodic review process to ensure compliance with this policy can help prevent future occurrences. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-010 – Procurement (Material Weakness and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Department of the Treasury (CRF). Criteria: 2 CFR 200.317-327 establishes procurement standards for nonfederal entities. This includes different requirements based on the amount of purchases made from the vendor during the year. Specifically, 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. Per the City’s Fiscal Policy and Procedures Manual, the simplified acquisition method has a lower threshold of $15,000. All contracts and purchases over $15,000 must be bid. Condition: We selected eight vendors for procurement testing. Of those eight, it was noted that for five vendors the City did not document the appropriate procurement procedures took place. Cause: Minority Health - the City contracted or accumulated costs for four vendors over the simplified acquisition threshold and did not provide documentation of bid procedures. CRF - the City contracted one vendor over the simplified acquisition threshold and did not provide documentation of bid procedures. Effect: The City did not have appropriate documentation to support compliance with the procurement policy. Questioned Costs: Minority Health - $433,369; CRF - $22,813 Recommendation: We recommend the City reinforce its procurement policies through regular training and clear communication to all relevant staff members. Additionally, implementing a periodic review process to ensure compliance with this policy can help prevent future occurrences. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.
All Funding Sources Significant Deficiency Procurement Criteria Condition Cause Effect Recommendation Management's Response An entity must have and use documented procurement policies consistent with Federal, State, and local laws, regulations, and standards for the acquisition of property or services required under a Federal award or subaward. The procedures must conform to the procurement standards identified in CFR § 200.317 through 200.327. Management agrees with our recommendation and finding and will work to implement a policy. The entity has continued to reference specific grant manuals and guidelines as its written procurement policy. We recommend management develop and adhere to an internally developed policy for all procurements using Federally sourced funds. The Center maintains specific grant manuals and guidelines as its written policies; however, previous audit identified errors in misapplying grant guidelines among funding sources. A recommendation was made in previous audit to develop a policy that would cover all procurements using Federally sourced funds. Such policy was not developed. Failure to follow appropriate procurement procedures could result in excess procurement costs being disallowed and subject the entity to possible claims.